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HomeMy WebLinkAboutNC0077135_NOD2017PC0216_20170717Water Resources M°d9R©NMENTAL QUAUTY July 28, 2017 Fred D. Curl Curl Modular Homes 707 N English St Greensboro, NC 27405 Subject: Compliance Evaluation Inspection Report and Notice of Deficiency Tracking Number: NOD -2017 -PC -0216 NPDES Permit NCO077135 Hidden Valley WWTP, Rockingham County Dear Mr. Curl: MICHAEL S. REGAN secretory S. JAY 2llw MERMAN 1)tmctor On July 17, 2017, Paul DiMatteo of the Division of Water Resources ("Division"), Winston-Salem Regional Office conducted a Compliance Evaluation Inspection of the above referenced wastewater treatment system. Paul Smith, Operator in Responsible Charge (ORC), was present for the inspection. An inspection summary follows and an inspection report is attached for your records. Site Review 1. Permit The current permit became effective on June 1, 2017 and expires on April 30, 2022. A copy of the current permit was not available for review — one should be kept for inspection. Permitted components include an aeration basin, clarifier, and UV disinfection. 2. Facility Site Review The facility was as described in the permit. Flow is low compared to the permitted amount (permitted for 22,000 gpd; average reported flow over the last 2 years is about 150 gpd). 3. Operation and Maintenance —Non -Compliant The operator or a properly designated backup visits the site as required. Visitation logs were current and available during the inspection. The following maintenance issues were noted during the inspection: a. The drive unit for the skimming system on the circular clarifier was not operational. The ORC reported an issue with the arm catching on the skimmer. There was no timeline for repair. It State of North Carolina I Environmental Quality I Water Resources 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 was also noted that there was some algae growth on the outer weir in the clarifier and the weir did not appear level along its circumference. b. The bar screen did not appear to be fully in use. Some debris and grease accumulation was observed in the influent tank. The ORC said that effluent is pumped into the aeration basin through two macerating pumps that can break down some material, and that excess accumulations are pumped as needed. Part II, Section C.2 of your permit states that "the Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit." Although the plant appeared to be properly treating what waste it receives at the time of inspection, it should be noted that allowing components of the system to deteriorate may affect performance in the future, especially when flow is increased. The level of deterioration of this system has resulted in the rating of non-compliant and the subject Notice of Deficiency. 4. Flow Measurement The permit requires instantaneous flow measurement influent or effluent. Flow is measured using a v -notch weir after water is disinfected. The weir did not appear to be obstructed. 5. Effluent/Receiving Waters The effluent is discharged into an unnamed tributary to Lick Fork Creek. The outfall was accessible during the inspection. Effluent appeared clear with no visible impact to the receiving stream. Documentation Review 6. Records/Reports Discharge Monitoring Reports (DMRs) and lab data are maintained according to the permit. DMRs include all permit parameters. Copies of DMRs, operator visitation logs, lab reports and Chain -of - Custody forms were available for review during the inspection. 7. Self -Monitoring Program A review of DMRs from May, 2016 through May, 2017 showed no violations, and a comparison of submitted DMR data and field records showed no errors or concerns. 8. Laboratory Field parameters are measured by the ORC under certification # 5169 (Smith Industries). All effluent samples are taken from the aerobic digester. All other parameters are measured by Pace Analytical under certification # 633. Chain -of -custody forms were complete and available for all parameters measured off site. Records for parameters measured on-site were complete. 9. Sludge Handling Disposal Sludge is removed from the plant as needed., State of North Carolina I Environmental Quality I Water Resources 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Remedial actions should be taken to correct the deficiencies noted above and to prevent their occurrence in the future. Please be advised that, under state law, a civil penalty of up to $25,000 per violation may be assessed against any person who violates or fails to act in accordance with the terms, conditions or requirements of a permit (refer to Permit Conditions, Part II, Section B.1(f)). If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-9691 or our office at (336) 776-9800. Sincerely, N Sherri V. Knight, P.E., Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report and Summary CC: Paul Smith — by email WQS Winston-Salem Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File Central Files State of North Carolina I Environmental Quality I Water Resources 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 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 I 3 I NCO077135 I11 12 17/07/17 17 18 I S I 19 I G I 20L] 211IIIII IIIIIIIIIII IIIIIII I I11111 llllIIIIIII 166 I Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----Reserved 67 70 I_ 71 I I 72 L N � 73I I 174 75 j_jJ80 LJ I I I 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) 11 50AM 17/07/17 17/06/01 Hidden Valley WWTP US Hwy 29 Business Exit Time/Date Permit Expiration Date Reidsville NC 27320 12 50PM 17/07/17 22/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Paul Matthew Smith/ORC/336-932-9347/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Fred D Curl,707 N English St Greensboro NC 27405/Owner/336-379-9155/3363799155 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 Paul DiMatteo WSRO WQ//336-776-9691/ �� % :9 7f 2Zv7�a7 a� Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date G,6 'f-C9,1 ti V 71,17/1017 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete Page# NPDES yr/mo/day Inspection Type (Cont.) 1 31 NCO077136 111 121 17/07/17 117 18 I „ Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Site Review 1. Permit The current permit became effective on June 1, 2017 and expires on April 30, 2022. A copy of the current permit was not available for review — one should be kept for Inspection. Permitted components Include an aeration basin, clarifier, and UV disinfection. 2. Facility Site Review The facility was as described in the permit. Flow is low compared to the permitted amount (permitted for 22,000 gpd; average reported flow over the last 2 years is about 150 gpd). I 3. Operation and Maintenance — Non -Compliant The operator or a properly designated backup visits the site as required. Visitation logs were current and available during the inspection. The following maintenance Issues were noted during the inspection: a. The drive unit for the skimming system on the circular clarifier was not operational. The ORC reported an issue with the arm catching on the skimmer. There was no timeline for repair. It was also noted that there was some algae growth on the outer weir in the clarifier and the weir did not appear level along Its circumference. b The bar screen did not appear to be fully in use. Some debris and grease accumulation was observed in the influent tank. The ORC said that effluent is pumped Into the aeration basin through two macerating pumps that can break down some material, and that excess accumulations are pumped as needed Part II, Section C.2 of your permit states that "the Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit." Although the plant appeared to be properly treating what waste it receives at the time of inspection, it should be noted that allowing components of the system to deteriorate may affect performance in the future, especially when flow is increased. The level of deterioration of this system has resulted in the rating of non-compliant and the subject Notice of Deficiency. 4. Flow Measurement The permit requires instantaneous flow measurement influent or effluent. Flow is measured using a v -notch weir after water is disinfected. The weir did not appear to be obstructed. 5. Effluent/Receiving Waters The effluent is discharged Into an unnamed tributary to Lick Fork Creek. The outfall was accessible during the inspection. Effluent appeared clear with no visible impact to the receiving stream. Documentation Review 6. Records/Reports Discharge Monitoring Reports (DMRs) and lab data are maintained according to the permit. DMRs include all permit parameters. Copies of DMRs, operator visitation logs, lab reports and Chain -of -Custody forms were available for review during the inspection. 7. Self -Monitoring Program Page# 2 Permit: NCO077135 Inspection Date- 07/17/2017 Owner - Facility Hidden Valley WWTP Inspection Type. Compliance Evaluation A review of DMRs from May, 2016 through May, 2017 showed no violations, and a comparison of submitted DMR data and field records showed no errors or concerns. 8. Laboratory Field parameters are measured by the ORC under certification # 5169 (Smith Industries) All effluent samples are taken from the aerobic digester. All other parameters are measured by Pace Analytical under certification # 633. Chain -of -custody forms were complete and available for all parameters measured off site. Records for parameters measured on-site were complete. 9. Sludge Handling Disposal Sludge is removed from the plant as needed Page# Permit NCO077135 Owner - Facility Hidden Valley WWTP Inspection Date- 07/17/2017 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: DO, PH, Settleable Solids 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? ❑ M ❑ ❑ 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 Keepinq 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? 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? ❑ ❑ ❑ (if the facility Is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator ❑ ❑ 0 ❑ on each shift? I Is the ORC visitation log available and current? M ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? M ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? M ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ Page# 4 Permit: NCO077135 Inspection Date- 07/17/2017 Record Keeping Facility has copy of previous year's Annual Report on file for review? Owner - Facility. Hidden Valley WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ■ ❑ Comment. ORC had an old copy of the permit available (current permit came into effect June 1, 2017) 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 Flow Measurement - Effluent # 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment- Requirement Is Instantaneous, weekly Measured using a V -Notch Weir after the clarifier. Weir appeared unobstructed. Bar Screens Yes No NA NE Type of bar screen ❑ ❑ N a Manual Is the basin free of bypass lines or structures to the natural environment? 0 ❑ b.Mechanical ❑ Is the basin free of excessive grease? 0 Are the bars adequately screening debris? ❑ ❑ ❑ Is the screen free of excessive debris? ❑ ❑ ❑ 0 Is disposal of screening in compliance? ❑ ❑ ❑ s Is the unit in good condition? ❑ ❑ ❑ N Comment- ORC reported the bar screen is not really in use. Mascerator pumps are used to decrease the particle size, and debris is pumped as needed, but some buildup of -grease and debris was observed. Equalization Basins Yes No NA NE Is the basin aerated? ❑ ❑ N ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Page# 5 Permit: NCO077135 Owner - Facility Hidden Valley WWTP Is the clarifier free of black and odorous wastewater? 0 ❑ Inspection Date: 07/17/2017 Inspection Type: Compliance Evaluation Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ Equalization Basins Yes No NA NE Are float controls operable? E ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ❑ 0 # Is basin size/volume adequate? E ❑ ❑ ❑ Comment 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? 0 ❑ ❑ ❑ Are weirs level? ❑ 0 ❑ ❑ Is the site free of weir blockage? ❑ ❑ ❑ Is the site free of evidence of short-circuiting? N ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? Is the foam the proper color for the treatment process? ❑ ❑ ❑ Is the drive unit operational? ❑ 0 ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? N ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) ❑ ❑ ❑ 0 Comment- Drive unit does not work. Weirs did not appear to be comDletely level - one side appeared about an Inch lower than the other. There was some sludge buildup was some algae growth on the outer weirs. According to the ORC, In the center well. There petting the drive unit fixed has not been a priority because of prolonged low flow compared to designed flow. Effluent appeared clear. i Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ N ❑ Are the diffusers operational? N ❑ ❑ ❑ Is the foam the proper color for the treatment process? N ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ E Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ 0 Comment- Color was somewhat dilute, reportedly due to low flow compared to design flow Page# 6 Permit: NCO077135 Owner - Facility Hidden Valley WWTP Inspection Date 07/17/2017 Inspection Type Compliance Evaluation Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? ❑ ❑ ❑ ❑ Are UV bulbs clean? N ❑ ❑ ❑ Is UV Intensity adequate? ❑ ❑ ❑ 0 Is transmittance at or above designed level? ❑ ❑ ❑ 0 Is there a backup system on site? ❑ 0 ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment. ORC reported that extra bulbs are kept at his house (about 10 minutes away) due to theft concerns. Likewise, backup chlorine tablets are available for use at other plants this ORC operates. Intensity and transmittance assumed adequate based on fecal coliform analyses. Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by Interrupting primary power source? N ❑ ❑ ❑ Is the generator tested under load? M ❑ ❑ ❑ Was generator tested & operational during the inspection? ❑ ❑ ❑ 0 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? ❑ ❑ ❑ 0 Is the generator fuel level monitored? ❑ ❑ ❑ 0 Comment: ORC reportedly does not manage the backup Dower system himself, but said that it was operating Properly. Could not be tested at the time of Inspection Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ Septic Tank Yes No NA NE (If pumps are used) Is an audible and visual alarm operational? ❑ ❑ 0 ❑ Is septic tank pumped on a schedule? N ❑ ❑ ❑ Are pumps or syphons operating properly? ❑ ❑ M ❑ Are high and low water alarms operating properly? ❑ ❑ 0 ❑ Comment- Septic tank used to hold sludge. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? ❑ N ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees ❑ ❑ ❑ M Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0 2 degrees? ❑ ❑ ❑ 0 Page# 7 Permit: NCO077135 Inspection Date: 07/17/2017 Laboratory Incubator (BOD) set to 20 0 degrees Celsius +/_ 1.0 degrees? Owner - Facility: Hidden Valley WWTP Inspection Type Compliance Evaluation Yes No NA NE ❑ ❑ ❑ 0 Comment. Calibration records were not available for review. The ORC reportedly uses an infrared thermometer for all temperature readings. He was Informed that certified lab rules don't allow infrared thermometers to be used for temperature readings reported on the DMR. He said he would obtain and use another thermometer. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ ❑ Is sample collected below all treatment units? M ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ M ❑ # 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 0 ❑ ❑ ❑ representative)? Comment - Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and N ❑ ❑ ❑ sampling location)? Comment - IPage# 8