NC0001643_NOD2017PC0215_20170717

v
WarerResources
EEViRONMENTAL QUAUTY
July 27, 2017
Edward Massood
Eden Real Estate Associates LLC
572 S New Street
Eden, NC 27288
Subject: Compliance Evaluation Inspection Report and Notice of Deficiency
Tracking Number: NOD -2017 -PC -0215
NPDES Permit NC0001643
Eden Real Estate WWTP, Rockingham County
Dear Mr. Massood:
ROY COOPER,
t;a7wmar
MICHAEL S. RECAN
keraary
S. JAY ZIMMERMAN
Dhvrtor
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 July 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, clarifiers, and chlorine disinfection.
The facility is currently permitted to discharge up to an average of 0.5 mgd of domestic
wastewater, non -contact cooling water and boiler blowdown. Average flow from October, 2015 to
May, 2017 has been about 0.001 mgd. Due to the prolonged low flow, certain modifications were
made, and some components have been allowed to deteriorate, as detailed below. Please note
that, should the facility be changed such that the plant will receive nondomestic wastewater, part I,
condition A(2) of the permit requires submission of a request for permit modification at least 180
days prior to such a change. Also note that, should the plant receive significantly more domestic
wastewater, the deteriorated components may need to be repaired to achieve adequate treatment
and compliance with discharge limitations.
State of North Carolina I Environmental Quality I Water Resources
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105

2. Facility Site Review j
The facility was as described in the permit. However, the system has been slightly modified.
Currently, wastewater is discharge directly into the aeration basin, bypassing the mechanical bar
screen. Water is contained in the aeration basin until there has been enough accumulation to
warrant a discharge — recently, a discharge has occurred every 4 to 6 months. Once enough water
has accumulated, the ORC inserts a small pump into the aeration basin and pumps to one of the
clarifiers to allow settling of solids. Chlorine disinfection tablets are also inserted at this point.
Water then flows through the chlorine contact chamber, is dechlorinated, and flows to the outfall.
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:
a. Influent lift pumps and mechanical bar screens are not in use
b. Only one (of two) clarifier is in use. This clarifier was noted to have significant vegetal growth,
nonfunctional skimmer, and corrosion in the central ring.
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
Flow is calculated manually by multiplying the portable pump's run time with its flow rate.
5. Effluent/Receiving Waters
The effluent is discharged into the Dan River. The outfall was accessible during the inspection. A
trickle was observed to be discharging at the time of inspection. The effluent appeared clear with
no impacted to the receiving stream.
Documentation Review
i
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.
i
State of North Carohna I Environmental Quality I Water Resources
450 West Hanes Mill Road, - Suite 300, Winston-Salem, NC 27105

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.
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 [phone] or
our office at [phone].
Sincerely,
Fo'/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 NC0001643 111 12 17/07/17 17 18 Li i 19 L!1 20I I
21111111 11111111111 1111111 1 111111 11111111111 16
— Reserved ---
Inspection Work Days Facility Self-Monitoring Evaluation Rating 61 QA ---Reserved--
67 70 I I 71 I I 72 IJ N 731 I 174 75 80
67
L J LI 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)
01 20PM 17/07/17
17/06/01
MGM Transport WWTP
Exit Time/Date
permit Expiration Date
572 S New St
02 20PM 17/07/17
22/04/30
Eden NC 27288
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible OfriciallTitle/Phone and Fax Number
Contacted
Edward Massood,572 5 New St Eden NC 27288//336-635-4500/
No
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit N Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program 0 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 DiMa�t eo WSRO WQ//336-776-9691/ I
*D
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
a-eeam' � 7/X' /. "/7
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 NC0001643 I11 12 17/07/17 17 18 I c,
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 July 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, clarifiers, and chlorine disinfection.
The facility is currently permitted to discharge up to an average of 0.5 mgd of domestic wastewater,
non -contact cooling water and boiler blowdown. Average flow from October, 2015 to May, 2017 has
been about 0.001 mgd. Due to the prolonged low flow, certain modifications were made, and some
components have been allowed to deteriorate, as detailed below. Please note that, should the facility
be changed such that the plant will receive nondomestic wastewater, part I, condition A(2) of the permit
requires submission of a request for permit modification at least 180 days prior to such a change. Also
note that, should the plant receive significantly more domestic wastewater, the deteriorated
components may need to be repaired to achieve adequate treatment and compliance with discharge
limitations.
2. Facility Site Review
The facility was as described in the permit. However, the system has been slightly modified. Currently,
wastewater is discharge directly into the aeration basin, bypassing the mechanical bar screen. Water
is contained in the aeration basin until there has been enough accumulation to warrant a discharge —
recently, a discharge has occurred every 4 to 6 months. Once enough water has accumulated, the
ORC inserts a small pump into the aeration basin and pumps to one of the clarifiers to allow settling of
solids. Chlorine disinfection tablets are also inserted at this point Water then flows through the chlorine
contact chamber, is dechlorinated, and flows to the outfall.
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.
a. Influent lift pumps and mechanical bar screens are not in use
b. Only one (of two) clarifier is in use. This clarifier was noted to have significant vegetal growth,
nonfunctional skimmer, and corrosion in the central ring.
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.
I
4. Flow Measurement
Flow is calculated manually by multiplying the portable pump's run time with its flow rate.
5. Effluent/Receiving Waters
The effluent is discharged into the Dan River. The outfall was accessible during the inspection. A trickle
was observed to be discharging at the time of inspection. The effluent appeared clear with no impacted
Page#

Permit: NC0001643
Owner - Facility. MGM Transport WWTP
Inspection Date 07/17/2017 Inspection Type* Compliance Evaluation
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.
Page#

t�
Permit. NC0001643 Owner - Facility MGM Transport 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 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Facility seems to be weratinq well to treat the flow it is currently receiving but there are
some maintenance issues, especially with the clarifiers that would need to be addressed
before returning to a higher flow.
Permit
(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?
Yes No NA NE
❑ ❑ ■ ❑
■ ❑ ❑ ❑
N ❑ ❑ ❑
■ ❑ ❑ ❑
N ❑ ❑ ❑
Comment Facility is currently permitted to discharge non -contact cooling water, boiler blowdown and
domestic wastewater. Part I. Condition A.(2) of the permit requires notification before a
change of use resulting in receiving other than domestic wastewater.
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)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
E
❑
❑
❑
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?
I
N
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
N
❑
(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? 0 ❑ ❑ ❑
Is the ORC certified at grade equal to;or higher than the facility classification? ❑ ❑ ❑
Page# 4

J
Permit: NC0001643 Owner - Facility MGM Transport W WTP
Inspection Date: 07/17/2017 Inspection Type Compliance Evaluation
Record Keeping
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?
Comment: ORC did not have a copy of the current permit with him.
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
❑ ❑ N ❑
❑ ❑ N ❑
❑ ❑ ■ ❑
❑ ❑ N ❑
Comment: ORC obtains discharge flow by manually inserting a small pump into the aeration basin and
pumping to one of the clarifiers. Flow is calculated from the pump run time.
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? ❑ ❑ E ❑
Comment: Small trickle at the time of inspection.
Aeration Basins
Yes No NA NE
Mode of operation
Ext Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
0 ❑
❑
❑
Are the diffusers operational?
❑ ❑
0
❑
Is the foam the proper color for the treatment process?
❑ ❑
0
❑
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)
❑ ❑
❑
Comment. Water in the aeration basin was greenish and fairly clear
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? 1113 M ❑
Page# 5

Permit- NC0001643 Owner - Facility. MGM Transport WWTP
Yes No NA NE
Type of system ?
Tablet
Inspection Date. 07/17/2017 Inspection Type- Compliance Evaluation
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑
❑
Secondary Clarifier
Yes No NA NE
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?
❑
0
❑
❑
Is scum removal adequate?
❑
❑
N
❑
Is the site free of excessive floating sludge?
❑
❑
0
❑
Is the drive unit operational?
❑
E
❑
❑
Is the return rate acceptable (low turbulence)?
❑
❑
N
❑
Is the overflow clear of excessive solids/pin floc?
❑
❑
0
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
❑
❑
E
❑
Comment: ORC pumps water from the aeration_ basin to the clarifier when discharging. Only 1 (of 2) is
in use. This clarifier had vegetation growing in the outermost ring, corrosion completely
penetrating the center ring, and weir blockage.
Disinfection -Tablet Yes No NA NE
Are tablet chlorinators operational? ❑ ❑ 0 ❑
Are the tablets the proper size and type? E ❑ ❑ ❑
Number of tubes in use?
Is the level of chlorine residual acceptable? ❑ ❑ ❑ N
Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ 0
Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ 0
Comment- Chlorine tablets are added to the clarifier to achieve disinfection.
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑
❑
❑
Is storage appropriate for cylinders?
❑
❑
N
❑
# Is de -chlorination substance stored away from chlorine containers?
❑
❑
❑
I
Comment: /
Are the tablets the proper size and type?
0
❑
❑
❑
Are tablet de -chlorinators operational?
❑
❑
0
❑
Number of tubes in use?
Comment Dechlorination tablets are added at the end of the chlorine contact chamber (which is
currently not used for chlorine contact), before discharge.
Page# 6

Permit NC0001643 Owner - Facility MGM Transport WWTP
Inspection Date: 07/17/2017 Inspection Type Compliance Evaluation
De -chlorination Yes No NA NE
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?
M
❑
❑
❑
# 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)?
❑
❑
❑
M
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0 2 degrees?
❑
❑
❑
0
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
❑
0
Comment ORC reportedly measures temperature using an infrared thermometer. 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 a proper thermometer.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
M
❑
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
❑
❑
❑
0
representative)?
Comment ORC reportedly collects composite samples by hand, by collecting aliquots throughout the
day and storing them in the refrigerator in the on-site lab.
Page# 7