NC0025461_NOV-2015-PC-0315_20151217

PAT MCCRORY
(rovcmnr
DONALD R. VAN DER VAART
Secret rb
S. JAY ZIMMERMAN
Water Resources
Uireclor
ENVIRONMENTAL QUALITY
December 17, 2015
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7014 0510 0000 4466 8253
Charles Vines RECEIVEDIDENRODWR
Torn of Bakersville
PO Box 53 2 {;1
Bakersville, NC 28705
Water t.tua+tcy
Permitting Section
SUBJECT: NOTICE OF VIOLATION
NOV-2015-PC-0315
Compliance Evaluation Inspection
Bakersville WWTP
Permit No: NCO025461
Mitchell County
Dear Mr. Vines:
On September 21, 2015 and October 12, 2015, Linda Wiggs conducted compliance inspections at the
Bakersville Wastewater"treatment Plant (WWTP). Jadd Brewer, the WWTP operator, was present at both
inspections. The treatment facility was found to be non-compliant at both inspections. Several of the areas in
need of attention at the September 21, 2015, inspection were remediated. Those areas include the bar screen,
the EQ basin and the disinfection (UV) system. The Town's responsiveness to those items is appreciated.
I lowever, the October 12, 2015 inspection also had areas that need attention. The most notable appeared to be
related to Operations and Maintenance (Part II Section C. 2.); the decanting device appeared to be
malfunctioning. it is unclear what cycles the SBR was operating and the flows observed fluctuated
significantly affecting effluent duality and flow measurements. Photos on the following pages indicate the
flow concerns. Please refer to the enclosed inspection report for detailed inspection comments and other
items in need of your attention.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within thirty(30) days of receipt of this letter. You should address the causes of noncompliance
and all actions taken to prevent the recurrence of similar situations. -
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone.[phone] FAX:[phone]
Internet:http:l/pogal.ncdenr.org/web/wq/
An Equal Opportunity\Affirmative Action Employer
G\WRyWQAMitchell\WastewaterAMunicipal'2546I BakersvilleANOV-2015-PC-0315.Inspect I I-12-2015.doex

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Town ofAakersville
December 17,2015
Page 3 of 4
Full V-Notch Weir Flow
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Digital and Chart Read Out Associated with Full V-Notch Weir Flow
1
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Town of Sakersville
Deeniber 17,2015
Page 4 of 4
If you have any questions, please do not hesitate to contact Linda Wiggs at 828-296-400.
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
Enc. Inspection Report
cc: Jadd Brewer. ORC
NPDES Unit
MSC 1617-Central Files-Basement
ARO Files
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i
United States Fnvironmental Protection Agency Form Approved.
EPA Washington,D.0 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 J IN � 2 �5 � 3 I NCO025461 I11 12 15/11/12 17 18� l 19 [G 201 I
211 L1 1 1 1 L I l l l l 11 l 1 l l l l l l l l l l l l l l l l l l l l l i l l l l l l t66
Inspection Work Days Facility Seif-Monitoring Evaluation Rating B1 QA ------------------Reserved-----------
67 70I I 71 1 I 72 1 N 731 I 174 75 80
LJ Section B Facility—JData
u 11 I
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) 10 OOAM 15/11/12 11/03/01
Bakersville WvVTP
Exit Time/Date Permit Expiration Date
306 S Mitchell Ave
11 30AM 15/11/12 16102/29
Bakersville NC 28705
Name(s)of Onsite Represenfative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
III
Name,Address of Responsible Official/TitlerPhone and Fax Number
Contacted
Charles VIneS,FO Box 53 Bakersville NC 28705//828-688-2113/
Yes
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit Flow Measurement Operations&MaintenancE 0 Self-Monitoring Program
Facility Site Review Effluent/Receiving Waters
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
Linda S Wiggs%; /r�Pi ARO WQ//828-296-4500 Ext 46531
c V"
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

NPDES yr/mo/day Inspection Type 1
31 NCO025461 I11 12 15/11/12 17 18 I S 1 (Cont.)
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Present during the inspection was Jadd Brewer(ORC). We met with Charles Vines(Town Mgr)
afterwards to discuss findings.
Permit Renewal: (Part If Section C. 9. & 10.)
To date, a renewal application has not been received according to the State's BIMS database.
ORC: (Part II Section C. 1.)
According to the State's BIMs database there is no ORC listed. Only BORCs are listed including one
that is invalid. It is understood that Jadd brewer is the ORC, however an ORC Designation Form needs
to be submitted to list the current ORC and BORC.
Reporting Requirements: (Reminder: Part II Section E. 6.)
There was evidence that a spill/bypass had occurred. The ORC had arrived at the facility a half hour
prior to the inspector and became aware of the incident.
SBR: (Part II Section C. 2.)
It is unclear how the SBR is set up to operate. The ORC stated the cycles are:aeration 25 minutes,
decant 10 minutes, aeration 25 minutes, decant 10 minutes, settle 30 minutes and decant 30 minutes.
There is only one settle cycle mentioned: decanting after aeration without settling is not typically how
SBR's function. The site specific SBR operational manual needs to be reviewed. The design Engineers
and/or the manufacturer may need to be consulted. It was discussed that neither had been onsite
since the installation. Another option the Town may need to consider is to request a Technical
Assistance visit from the State. -
The SBR has two basins; one is in use. The second basin cannot be used since the decant
mechanism motor is not working. If the motor in use fails there is not a replacement onsite. Staff _
stated it would take 24 hours to get another motor and there is a contingency pump plan if this were to
occur. This is pertinent since during the inspection the decant mechanism was having issues rising _
and lowering as the ORC attempted to maneuver it. There was also grease/oil residuals noted near the
decant mechanism motor.
Discharge from the SBR to the effluent varied extremely, from what appeared to be normal flows at half
weir to excessive flows at full weir. In concert with the flow variability solids were apparent in the
effluent as noted below in the grab TSS sample results.
Flow Monitoring/Sampling: (Part II Section A.(Composite Sample& Continuous Flow Measurement),
Part II Section D. 1.&3.)
It is unclear if proper flow monitoring and, therefore, proper composite sampling is occurring. At the
time of the inspection when the flows were at half the weir height, the digital read out indicated 254 -
and the chart recorder indicated—50 (TSS sample result was 9.5 mg/1). Then the flows increased to
the top of the weir and the digital read out went to 0 and the chart recorder maxed out then went to 0
(TSS sample result was 55 mg/I). If the`low mete; iS ,,i'rvori:ii y prcNcrly and is registering 0 when '
flows are very elevated, then proper flow composite samples cannot be obtained.
The paper in the chart recorder had been reused. It had recorded what appeared to be 3 weeks of flow
information and the most current readings were spiking severely between 0-100. The flow on the chart
recorder did not appear to match the digital read out.
:i
Page# 2

Permit: NCO025461 Owner-Facility: Bakersville WWfP
Inspection Date: 11/12/2015 Inspection Type: Compliance Sampling
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? ❑ ❑ ❑
Comment: To date, a renewal application has not been received according to the BIMs database. Mr.
Vines will check to make sure the renewal has been sent.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ N ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleab!e ❑ N ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: There was evidence that a spill/bypass had occurred.
The process controls should be documented in ORC log.
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? ❑ ❑ ❑ _
Are float controls operable? ❑ ❑ ❑
Are audible and visual alarms operable? ❑ ❑ ❑
#Is basin size/volume adequate? 0 ❑ ❑ ❑
Comment: It appears the float which initiates the pumps to send the water from the EQ basin to the
SBR is functioning. However, for the duration that the water was being delivered to the SBR,
the audio and visual alarm were activated. The alarms are meant to be high water alarms,
not alarms for normal flows being delivered to the SBR.
Bar Screens _ Yes No NA NE
4
Type of bar screen
a.Manual
b.Mechanical ❑
a
Are the bars adequately screening debris? 0 ❑ ❑ ❑
Is the screen free of excessive debris? ❑ ❑ ❑
Page# 3

Permit: NCO025461 Owner-Facility: BakersvilleWWrP
Inspection Date: 11/12/2015 Inspection Type: compliance Sampling
Bar Screens Yes No NA NE
Is disposal of screening in compliance? ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment: The Town cleaned the EQ since the last inspection as requested.
Sequencing Batch Reactors Yes No NA NE
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? ❑ 0 ❑ ❑
The operator understands and can explain the process? ❑ N ❑ ❑
Comment. The SBR has two basins but only one is in use. The second basin cannot be used since the
decant mechanism motor is not working. If the motor in use fails there is not a replacement.
Staff stated it would take 24 hours to get another motor and there is a contingency pump
plan if this were to occur. This is especially concerning since during the inspection the
decant mechanism was having issues rising and lowering as the ORC attempted to
maneuver it. There was also a grease/oil residual noted near the decant mechanism motor.
Solids were apparent in the effluent. It is unclear how this SBR is set up to operate. The
ORC stated the cycles are: aeration. 25 minutes decant 10 minutes. aeration 25 minutes,
decant 10 minutes, settle 30 minutes and decant 30 minutes. See summary for more
details.
Disinfection - UV Yes No NA NE
Are extra UV bulbs available on site? ❑ ❑ ❑
Are UV bulbs clean? 0 ❑ ❑ ❑
Is UV intensity adequate? N ❑ ❑ ❑
Is transmittance at or above designed level? E ❑ ❑ ❑
Is there a backup system on site? M ❑ ❑ ❑
Is effluent clear and free of solids? ❑ M ❑ ❑
Comment: One bulb was broken all other stacks were illuminated and appeared to be functioning
adequately.
Fecal sample result: 21 col/100ml
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting? 0 ❑ ❑ ❑
Is flow meter calibrated annually? 0 ❑ ❑ ❑
Is the flow meter operational? ❑ M ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ 0 ❑ ❑
Page# 4

Permit: NCO025461 Owner-Facility: BakersvilleWWTP
Inspection Date: 11/12/2015 Inspection Type: Compliance Sampling
Flow Measurement- Effluent Yes No NA NE
Comment: The chart recorder needed paper. The paper present had been reused. It appeared to
present 3 weeks of information.
What appeared to be the most current readings were spiking severely between 0-100. The
flow on the chart recorder did not appear to match the digital read out.At the time of the
inspection when the flows were at half the weir height the digital read out indicated 254 and
the chart recorder indicated—50. Then the flows increased to lust shy of the top of the weir
and the digital read out went to 0 and the chart recorder also went to 0.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ M ❑ ❑
Is sample collected below all treatment units? N ❑ ❑ ❑
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 degrees 0 ❑ ❑ ❑
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type ❑ M ❑ ❑
representative)?
Comment: As noted above if the flow meter is not working properly and is registering 0 when flows are
very elevated then proper flow composite samples cannot be obtained. nor would it be a
representative sample. See summary for more details.
Page# 5 _