NC0021547_NOV20170368_20170623

I
6A
W"el�fiof
n;M11keN:r�,� �=
Certified Mail #7016 1370 00016571 9S29
Return Receipt Requested
June 20, 2017
Summer Woodard, Manager Town
Town of Franklin
PO Box 1479
Franklin, NC 28744-1479
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2017-PC-0368
Permit No. NCO021547
Franklin WWTP
Macon County
Dear Permittee:
ROY COOPER,
fro
MICHAEL S. REGAN
lwadt lr
S. JAY ZIMMERMAN
ArWor
RECENEDINCDECIDWR
JUN 2 3 2017
Water 0 Stion
Permittingec
The North Carolina Division of Water Resources conducted a Compliance Evaluation Inspection of the Franklin
WWTP on June 7, 2017. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in NPDES WW Permit No. NC0021547. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Permit A Bypass of the treatment facility to the ground surface was occurring at the time
of the inspection. [NC0021547 Part II. C. 4(c) Prohibition of Bypass; Bypass from the
treatment facility is prohibited and the Permit Issuing Authority may take enforcement action
against a Permittee.]
Corrective Measures:
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
State of North Carolina I Environmental Quality Water Resources
2090 U S 70 Highway, Swannanoa, NC 28778
828-296-4500

To prevent further action, please respond in writing to this office within 15 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable. 1
If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
G. Landon Davidson, P.G.,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
Cc: Bill Deal, ORC
WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

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 15 1 3 I N00021547 111 12 17/06/07 17 18 t C I 19 I G I 20L]
21111111 111111111 11111 1111 1111111 11111111111 l66
I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -Reserved
67 70 LI I 71 � LJ 1 72 N 73 Lj 751 I I I I I I 180
J
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)
10 OOAM 17/06!07
12/12101
Franklin WWTP
Sierra Dr
Exit Time/Date
Permit Expiration Date
Franklin NC 28734
12 10PM 17/06/07
17/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
William Logan Deal/ORC/828-524-2516/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Sam Greenwood,PO Box 1479 Franklin NC 2874414791Town
Manager/828-524-2516/ No
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Pollution Prevention Facility Site Review
Effluent/Receiving Waters Other
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
Mikal Willmer ARO WQ//B28-296-4686/
_
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
(:L�_�
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete
Page#

NPDES yr/mo/day Inspection Type (Cont) 1
3I NCO021547 I11 12 17/06/07 17 18 1C1
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspector, Mikal Wlllmer, with the Asheville Regional Office conducted a Compliance Evaluation
Inspection of the Franklin WWTP on June 7, 2017 ORC, BIII Deal was present and assisted in the
inspection
Overall the plant was well maintained and operated, however, the system was determined to be
non-compliant with NPDES Permit Standard Conditions At the time of the inspection, a bypass of the
treatment system was noted Secondary effluent was/is seeping from a cracked manhole riser
upstream of the chlorine contact basin
I further discussed the bypass with Mr Deal on 6!8/2017 He informed me the leak had been occurring
for several years, but it was never mentioned in an inspection report or listed as a compliance issue
Mr Deal also stated plant staff were under the impression this was not classified as a bypass
An NOV is being issued with a request to abate the bypass as soon as possible A follow-up inspection
will be conducted to verify system compliance once we receive notification a repair is made Please
refer to the attached NOV for specific permit condition violations and requested corrective action
Page# 2
U

,i
Permit NCO021547 Owner - Facility Franklin WWTP
Inspection Date- 06/07/2017 Inspection Type Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable M ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment Overall the plant is clean and well maintained ORC states they analyze miss, pH, VSS and
Alkalinity DO is monitored by in-line DO meters
Permit
Yes No NA NE
(If the present permit expires In 6 months or less) Has the permittee submitted a new
0
❑
❑
❑
application?
M
❑
❑
❑
Is the facility as described In the permit?
M
❑
❑
❑
# 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
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab reg required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
M
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
M
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Page#
3

Permit. NCO021547
Inspection Date 06/07/2017
Record Keeping
Facility has copy of previous year's Annual Report on file for review?
Owner - Facility. Franklin WWTP
Inspection Type. Compliance Evaluation
Yes No NA NE
N ❑ ❑ ❑
Comment All external and Internal testina records are In binders within the laboratory and sorted b
year. The ORC also maintains a log of routine maintenance
Yes No NA NE
# Is composite sampling flow proportional?
❑
N
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
❑
N
❑
❑
Is flow meter calibrated annually?
S
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment An Influent flow meter Is located at headworks ORC states thev are averaaina about 1 MGD
coming Into the plant
Yes No NA NE
# Is composite sampling flow proportional?
❑
N
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?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment Ultrasonic flow meter is callbratec annually by Clearwater ORC reports, on average, flow Is
800,000 GPD leaving the plant
Influent Samplinq
Yes No NA NE
# Is composite sampling flow proportional?
❑
N
❑
❑
Is sample collected above side streams?
E
❑
❑
❑
Is proper volume collected?
❑
❑
❑
E
Is the tubing clean?
❑
❑
❑
E
# 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?
N
❑
❑
❑
Comment Facility has a refrigerated Influent sampler. ORC stated during the Inspection he believes the
Influent sampler Is set to time composite
Grit Removal
Type of grit removal
a Manual
b Mechanical
Yes No NA NE
Page# 4

1
Permit NCO021547
Owner - Facility Frandn wwTP
Type of bar screen
N
❑
Inspection Date 06/07/2017
Inspection Type Compliance Evaluation
a Manual
❑
❑
Grit Removal
Yes No NA NE
Is the grit free of excessive organic matter?
N
❑
❑
❑
Is the grit free of excessive odor?
®
❑
❑
❑
# Is disposal of grit in compliance?
0
❑
❑
❑
Comment Solids are hauled to the landfill from the headworks on Monday and Friday
Bar Screens
Yes No NA NE
Type of bar screen
N
❑
❑
❑
a Manual
❑
❑
❑
❑
b Mechanical
N
❑
❑
❑
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 The bar screen and headworks appeared to be operating effectively at the time of the
inspection ORC reports some issues with screen backups when septage haulers unload
ORC believes this is due to the septage station being so close to the headworks
Equalization Basins
Yes No NA NE
Is the basin aerated?
N
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
N
❑
❑
❑
Is the basin free of excessive grease?
N
❑
❑
❑
Are all pumps present?
❑
❑
E
❑
Are all pumps operable?
❑
❑
N
❑
Are float controls operable?
0
❑
❑
❑
Are audible and visual alarms operable?
0
❑
❑
❑
# Is basin size/volume adequate?
N
❑
❑
❑
Comment Audio and Visual alarms and SCADA were present and in use at the headworks Alarms are
checked regularly by VWVTP staff The 1 5 MGD EQ basin Is aerated and gravity feeds to
the WVTrP ORC reports the plant has seen surges to the top
of the EQ basin during heavy
rain and storm events
Oxidation Ditches
Yes No NA NE
Are the aerators operational?
0 ❑
❑
❑
Are the aerators free of excessive solids build up?
0 ❑
❑
❑
# Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Page# 5

Permit NCO021547 Owner - Facility
Inspection Date 06/07/2017 Inspection Type
Franklin WWTP
Compliance Evaluation
Is the clarifier free of black and odorous wastewater?
0
❑
Oxidation Ditches
Yes No NA NE
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
M
❑
❑`
❑
Are settleometer results acceptable (> 30 minutes)?
❑
❑
❑
N
Is the DO level acceptable?(1 0 to 3 0 mg/1)
0
❑
❑
❑
Are settelometer results acceptable?(400 to 800 ml/I In 30 minutes)
❑
❑
❑
0
Comment The oxidation ditch uses floating brush aerators connected to in-line HACH DO meters
ORC has the aerators set to turn on when DO drops below 0 5 mg/L. Mr Deal states they
aim to keep the DO between 0 5 and 1 mg/L. The plant is also in the process of upgrading
the drives on the aerators to improve performance ORC stated MLSS is generally 4000
mg/L within the oxidation ditch Sludge is wasted about three days a week
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?
M
❑
❑
❑
Are weirs level?
N
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
M
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
N
❑
❑
❑
Is the return rate acceptable (low turbulence)?
❑
❑
❑
0
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
❑
❑
❑
M
Comment Fiber glass weirs were leveled and Datched five vears ago Effluent from clarifier aDDeared
free of visible solids. No apparent build-up
in center well ORC reports they clean out the
center well as needed.
Pumps -RAS -WAS
Yes No NA NE
Are pumps in place?
0 ❑
❑
❑
Are pumps operational?
M ❑
❑
❑
Are there adequate spare parts and supplies on site?
0 ❑
❑
❑
Comment Two RAS pumps in operation. One RAS pump recently replaced. ORC states they have
budgeted to replace the second RAS pump The WAS pump is in good condition
Aerobic Digester
Is the capacity adequate?
Yes No NA NE
■ ❑ ❑ ❑
Page# 6

Permit N00021547
Inspection Date. 06/07/2017
Owner - Facility: Franklin WWTP
Inspection Type Compliance Evaluation
Aerobic Digester
Yes No NA NE
Is the mixing adequate?
M
❑
❑
❑
Is the site free of excessive foaming In the tank?
0
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment 1 MGD aerobic digester, three blower motors
(lead, lag, lag) supply air to the 15 diffusers
❑
❑
Digester is aerated 16-20 hours a day during
the summer and 4 hours during the winter
N
❑
❑
months
The facility has an approved sludge management plan?
M
❑
❑
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
E
❑
❑
❑
Is the chemical feed equipment operational?
N
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Is the site free of high level of solids In filtrate from filter presses or vacuum filters?
0
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
0
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
N
❑
❑
❑
The facility has an approved sludge management plan?
M
❑
❑
❑
Comment Belt filter press was not in operation at the time of the Inspection
Building Is well maintained
and equipment appeared to be clean and free of build-up The press
Is used to dry sludge
before hauling to the landfill
Disinfection -Liquid
Yes No NA NE
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
0
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
0
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
M
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
0
Comment Hvpochlonte feed Is flow proportional The residual prior to dechlorination Is not monitored
Fecal results are used as an Indicator of chlorine effectiveness ORC states the contact
chamber was cleaned of solids five years ago.
De -chlorination
Yes No NA NE
Type of system ?
Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ ❑
0
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
0 ❑
❑
❑
Page# 7

Permit NCO021547 Owner - Facility Franklin WWTP
Inspection Date 06/07/2017 Inspection Type Compliance Evaluation
De -chlorination Yes No NA NE
Are the tablets the proper size and type? ❑ ❑ ■ ❑
Comment The liquid sulfur dioxide is stored in a separate room from the hypochlorite
Are tablet de -chlorinators operational? ❑ ❑ M ❑
Number of tubes in use?
Comment
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
®
❑
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
M
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
M
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
❑
❑
representative)?
Comment Composite sampler thermometer is calibrated annually Sampler appeared to be new and
well maintained
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? M ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? M ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑
Comment Path is clear down to effluent pipe No visual Impairments of the receiving stream noted at
the time of Inspection
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
M ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
M ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page# 8

Permit NCO021547
Inspection Date 06/07/2017
Standby Power
Owner - Facility Franklin WWTP
Inspection Type Compliance Evaluation
Yes No NA NE
Comment This facility has two on-site generators One located at the headworks and one for the
WWTP and buildings on-site Both generators self -test on Wednesday under load
Generator self -tested during the Inspection
Other
Yes No NA NE
Comment A bypass was noted during the inspection A manhole directly before the chlorine contact
basin was slowly leaking secondary effluent See summary and attached NOV for details
Page#