NC0025453_Sams Branch_2024 Compliance Evaluation Inspection_20241119

November 19, 2024

Richard Cappola
Town of Clayton
PO Box 879
Clayton, NC 27528-0879

Subject: Compliance Evaluation Inspection
Sam’s Branch WRF
NPDES Permit NC0025453
Johnston County

Dear Ms. Cappola:

On Tuesday, November 5, 2024, Kevin Fowler conducted a compliance evaluation inspection of
the treatment systems located at Sam’s Branch WRF. The purpose of this visit was to conduct an
inspection of the subject NPDES facility. During the inspection, the presence and cooperation of
David White, Operator in Responsible Charge (ORC), was greatly appreciated.

Sam’s Branch WRF is located at 1000 Durham Street, Clayton, North Carolina 27502 in Wake
County. The plant has a Municipal Wastewater Discharge (Large) permit.

This NPDES compliance evaluation inspection consisted of the following:
 Review of the NPDES permit.
 Review of the owner/facility information.
 Review of December 2022 – October 2024 monitoring data.
 Review of December 2022 – October 2024 compliance history.
 On-site inspection of the treatment systems; and
 On-site inspection of discharge outfalls

Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Page 2 of 3
Sam’s Branch WRF
Compliance Inspection 2024
2
Findings during the pre-inspection file review were:

1. Through NPDES permit NC0025453, Sam’s Branch WRF is authorized to discharge treated
wastewater the Neuse River classified WS-IV;NSW,CA waters in the Neuse River Basin.
The current NPDES permit was issued effective January 15, 2021, and expired March 31,
2024. An application for renewal of this permit was received on September 19, 2023.
2. The plant provides treatment and discharge of wastewater through outfall pipe 001 to the
Neuse River. According to the division records the plant consist of the following units:
influent head works with a biofilter odor control system; mechanical and automatic bar
screens; a vortex type grit removal system; influent pump station with three (3) 60 Hp dry pit
submersible pumps and one (1) 40 Hp pump; a 214,500 gallon anaerobic selector tank; two
(2) oxidation ditches; a 200,000 gallon first stage anoxic tank; a 214,500 gallon anaerobic
basin; three (3) secondary clarifiers; two (2) shallow bed DAVCO traveling bridge type
tertiary filters; two (2) banks of UV disinfection with back-up chlorination/dichlorination;
effluent pump station; one (1) 90,000 gallon aerated digester/sludge stabilization tank; two
(2) 360,000 gallon aerated sludge holding tanks; sludge loading station; sludge thickening
building with two (2) rotary drum thickeners; and reclaimed water pump station.
3. For the review period December 2022 – November 2024, there were three notices of
violations issued. One of these was a limit violation for Nitrogen Ammonia, and the other
two were monitoring violations for Fecal Coliform and Conductivity respectively. There
have also been three reported bypass incidents for the review period. Two of incidents
involved power related issues that affected the effluent pumps. The third incident was due to
heavy rain caused by Tropical Storm Debby.

Findings during the inspection were:

4. The operator’s log and supporting inspection documentation were consistent and up to date.
5. DMR reports from February 2024, and June 2023 were brought to be compared to laboratory
analytical results. Two discrepancies were found while reviewing laboratory bench sheets.
The two discrepancies were concerning total KJEL nitrogen for February 2024 and copper
for June 2024 respectively. The two discrepancies appeared to be clerical data entry errors
and not willful or intentional. Plant staff indicated that revised reports will be submitted for
these two months.
6. The facility contains two back up power generators on-site. One Gregory Poole generator
which supplies back up power for the administrative building and the headworks. The
second generator is a Cummins brand one that supplies back up power to the rest of the plant
if needed. These generators are not included in the current permit and should be considered
for inclusion in future permits.
7. Past inspections indicated that there were two drum thickeners present for solids handling.
Plant staff indicated that one of these drum thickeners is no longer in use.
8. At the time of inspection, one of the Shallow Bed DAVCO traveling bridge tertiary filters
was out of service. Plant staff indicated they were waiting for a backwash pump which had
been ordered. Once this pump is received and installed the tertiary filter should be back in
operation.
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Page 3 of 3
Sam’s Branch WRF
Compliance Inspection 2024
3
9. Effluent sampling tubing was found to be dirty and contained algal growth. Plant staff
indicated that the tubing is typically replaced quarterly.
10. The 90,000-gallon aerated digester/sludge stabilization tank is only used to store collected
surface scum/solids from the clarifiers.
11. Plant staff indicated that the new 6 MGD plant being built near 1422 O-Neil Street is
projected to being completed in 2025. Once the new plant is brought online, the current
water reclamation facility is planned to be decommissioned.
12. Improvements have been made to the electrical system programming for the effluent pumps
which should help to reduce the risk of future bypass incidents.
13. Outfall 001 is located across town from the current plant near 35.664211, -78.425121. The
right of way was found to be well maintained. No evidence of solids found in receiving
waters near the outfall.

Within 30-days receipt of this letter, please submit a written response to this office indicating the
actions you will take or have taken to comply with or resolve the issues noted below.
1. eDMR Discrepancies: Please indicate in your response your plan to eliminate future data
entry errors in the facilities monthly discharge monitoring reports. Please also submit
any revised report needed with accurate data.

If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact Kevin Fowler at 919-437-0047 or via email at
[e-mail]

Sincerely,

Vanessa Manuel
Water Quality Regional Assistant Supervisor
Raleigh Regional Office

Attachments: EPA Water Compliance Inspection Report

Cc: Laserfische
David White (ORC)
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
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 NC0025453 24/11/05 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)
Sam's Branch WRF
1000 Durham St
Clayton NC 27520
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/11/05 21/02/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
01:30PM 24/11/05 24/03/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Steven Biggs,PO Box 879 Clayton NC 275280879/Town
Manager/919-553-5866/9195531541
Contacted
No
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
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
Kevin Fowler DWR/RRO WQ/919-791-4200/
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
11/7/2024
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
11/19/2024
NPDES yr/mo/day
24/11/05
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Findings during the pre-inspection file review were:
1.Through NPDES permit NC0025453, Sam’s Branch WRF is authorized to discharge treated
wastewater the Neuse River classified WS-IV;NSW,CA waters in the Neuse River Basin. The current
NPDES permit was issued effective January 15, 2021, and expired March 31, 2024. An application for
renewal of this permit was received on September 19, 2023.
2.The plant provides treatment and discharge of wastewater through outfall pipe 001 to the Neuse
River. According to the division records the plant consist of the following units: influent head works
with a biofilter odor control system; mechanical and automatic bar screens; a vortex type grit removal
system; influent pump station with three (3) 60 Hp dry pit submersible pumps and one (1) 40 Hp
pump; a 214,500 gallon anaerobic selector tank; two (2) oxidation ditches; a 200,000 gallon first
stage anoxic tank; a 214,500 gallon anaerobic basin; three (3) secondary clarifiers; two (2) shallow
bed DAVCO traveling bridge type tertiary filters; two (2) banks of UV disinfection with back-up
chlorination/dichlorination; effluent pump station; one (1) 90,000 gallon aerated digester/sludge
stabilization tank; two (2) 360,000 gallon aerated sludge holding tanks; sludge loading station; sludge
thickening building with two (2) rotary drum thickeners; and reclaimed water pump station.
3.For the review period December 2022 – November 2024, there were three notices of violations
issued. One of these was a limit violation for Nitrogen Ammonia, and the other two were monitoring
violations for Fecal Coliform and Conductivity respectively. There have also been three reported
bypass incidents for the review period. Two of incidents involved power related issues that affected
the effluent pumps. The third incident was due to heavy rain caused by Tropical Storm Debby.

Findings during the inspection were:
4.The operator’s log and supporting inspection documentation were consistent and up to date .
5.DMR reports from February 2024, and June 2023 were brought to be compared to laboratory
analytical results. Two discrepancies were found while reviewing laboratory bench sheets . The two
discrepancies were concerning total KJEL nitrogen for February 2024 and copper for June 2024
respectively. The two discrepancies appeared to be clerical data entry errors and not willful or
intentional. Plant staff indicated that revised reports will be submitted for these two months.
6.The facility contains two back up power generators on-site. One Gregory Poole generator which
supplies back up power for the administrative building and the headworks. The second generator is
a Cummins brand one that supplies back up power to the rest of the plant if needed. These
generators are not included in the current permit and should be considered for inclusion in future
permits.
7.Past inspections indicated that there were two drum thickeners present for solids handling. Plant
staff indicated that one of these drum thickeners is no longer in use.
8.At the time of inspection, one of the Shallow Bed DAVCO traveling bridge tertiary filters was out of
service. Plant staff indicated they were waiting for a backwash pump which had been ordered. Once
this pump is received and installed the tertiary filter should be back in operation.
9.Effluent sampling tubing was found to be dirty and contained algal growth. Plant staff indicated that
the tubing is typically replaced quarterly.
10.he 90,000-gallon aerated digester/sludge stabilization tank is only used to store collected surface
scum/solids from the clarifiers.
11.Plant staff indicated that the new 6 MGD plant being built near 1422 O-Neil Street is projected to
being completed in 2025. Once the new plant is brought online, the current water reclamation facility
is planned to be decommissioned.
12.Improvements have been made to the electrical system programming for the effluent pumps which
should help to reduce the risk of future bypass incidents.
13.Outfall 001 is located across town from the current plant near 35.664211, -78.425121. The right
of waywas found to be well maintained. No evidence of solids found in receiving waters near the
outfall.
NC0025453 17 (Cont.)
Page#2
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Within 30-days receipt of this letter, please submit a written response to this office indicating the
actions you will take or have taken to comply with or resolve the issues noted below.
1.eDMR Discrepancies: Please indicate in your response your plan to eliminate future data entry
errors in the facilities monthly discharge monitoring reports. Please also submit any revised report
needed with accurate data.
Page#3
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
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?
Permit expired 3/31/2024. Renewal application was submitted on 9/19/2024.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?
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?
Two data entry errors found on eDMR when compared to labratory analytical data.
The two errors were found for total KJEL nitrogen (February 2024) and copper (June
2024).
Comment:
Page#4
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
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?
# Is the facility using a contract lab?
# 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?
BOD is now handled by a contract lab.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?
Comment:
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?
Is disposal of screening in compliance?
Is the unit in good condition?
Biotrad odor control system present at headworks.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?
Page#5
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Pump Station - Influent Yes No NA NE
One way telemetry system set up to notify of station issues. No SCADA system
present. Checked weekly.
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?
Comment:
Flow Measurement - Influent 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?
Calibrated on 6/23/2024 by Chadwick Instruments.Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Vortex system. Patriot sanitization hauls seperated grit and screened material to
landfill.
Comment:
Oxidation Ditches Yes No NA NE
Are the aerators operational?
Are the aerators free of excessive solids build up?
# Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Page#6
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Oxidation Ditches Yes No NA NE
Is the DO level acceptable?
Are settleometer results acceptable (> 30 minutes)?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes)
Dissolved oxygen in on of the ditches was less than 1.0 mg'l. Plant staff indicated that
this is typical and is the level that gives them the best effluent results.
Comment:
Nutrient Removal Yes No NA NE
# Is total nitrogen removal required?
# Is total phosphorous removal required?
Type
# Is chemical feed required to sustain process?
Is nutrient removal process operating properly?
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)
Comment:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Page#7
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Comment:
Filtration (High Rate Tertiary)Yes No NA NE
Type of operation:
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?
One of the traveling bridge filters was down because a backwash pump has been
ordered and plant is awaiting arrival.
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?
Bulbs are self cleaning and outside contractor does annual maintenance.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?
Outfall is across down located near 35.664211, -78.425121.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?
Page#8
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Effluent Sampling Yes No NA NE
# 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)?
Sample tubing was dirty and contained alagal growth on day on inspection.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?
Calibrated June 23, 2024.Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
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?
One drum thickener in operation.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?
Page#9
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B
Permit:NC0025453
Inspection Date:11/05/2024
Owner - Facility:
Inspection Type:
Sam's Branch WRF
Compliance Evaluation
Aerobic Digester Yes No NA NE
Comment:
Pump Station - Effluent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
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?
One way dial telemetry available. Station checked weekly.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?
Comment:
Page#10
Docusign Envelope ID: 746BAC86-3A15-40F2-B71D-667E8872770B