NC0023876_Compliance Evaluation Inspection Report_20171108

Water Resources
Environmental Quality
November 8, 2017
Mr. Robert Patterson, Water Resources Director
City of Burlington
PO Box 1358
Burlington, NC 27216-1358
Subject: Compliance Evaluation Inspection Report
NPDES Permit NCO023876
South Burlington WWTP, Alamance County
Dear Mr. Patterson:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
ECEIVEDAICDECl WR
Nov 16 2017
1Nater Quality
perrnittir,ig Section
On October 11 and 25, 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. The presence and cooperation of both Mr. Rick Asher and Mr. Glenn McGirt was greatly
appreciated. This type of inspection consists of two basic parts: an on-site inspection of the facility and a
review of facility files and self-monitoring data. Observations from each area of the inspection are summarized
below.
Site Review
1. Permit
The current permit became effective on July 1, 2014 and expires on June 30, 2019. A copy of the
current permit was available for review. Permitted components include a 3.5 million gallon aerated
equalization basin, primary and secondary clarifiers, biological nutrient reduction, sand filtration,
and gas chlorination.
2. Facility Site Review
The facility was as described in the permit. At the time of Inspection, secondary clarifier #4 was
down for routine maintenance. It was noted during the previous inspection that the plant planned
to replace the gas chlorine disinfection system with liquid chlorine; however, Mr. Asher said that
the details had not yet been finalized. The backup power generator is tested under lead for one
hour every month. Mr. Asher said that if the generator's fuel tank is full it is capable of powering
the entire plant for about 2 days.
<5> Noti ing Compares -f__
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone. [phone] FAX [phone]

3. Operation and Maintenance
Rick Asher is the current Operator in Responsible Charge, and Mark Andrews and Elizabeth
Whitfield are backup ORCs. All operators are properly designated and hold the correct credentials.
However, as of the date of this letter Mr. Andrews has not received the required Continuing
Education hours for 2017.
The operators use the Hach Water Information Management Systems (WIMS) database to track
trends in the treatment process and integrate reporting and documentation, and the Hach JOB Cal
systemto track all preventative and repair work at the plant.
4. Flow Measurement
Both influent and effluent flow meters are checked every 3 months and calibrated at least once per
year by Carolina Tech. The meters were last calibrated in August, 2017. Only the effluent flow is
reported. For both influent and effluent flow measurement, a 2 foot Parshall flume is used as the
primary flow device, and an ultrasonic flow meter is used as the secondary device.
At the effluent, it appeared that the secondary device may not have been in the correct location for
accurately measuring flow. To ensure sufficient accuracy of reported flow data, please:
a. Verify that the secondary device is in the proper location and that the device and recorder
are accurate within 10% of the true flow value, and
b. Submit a copy of the next effluent flow meter calibration check and any accompanying
adjustments made to the meter to this office for review.
5. Effluent/Receiving Waters
The effluent is discharged to the Big Alamance Creek in the Cape Fear River Basin. In -stream
monitoring requirements have been waived as long as the City of Burlington remains a member of
the Upper Cape Fear River Basin Association.
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.
Please note that Permit Part I, Condition A(9) requires a mercury minimization plan to be
developed no later than January 1, 2015 and implemented during the permit term. A sample MMP
was developed and is available on the Division's website. During the inspection Mr. Asher was not
able to produce a copy of the sample MMP, but the facility's own plan was not available. Please
ensure that a plan has been developed and implemented, and keep a copy of the plan available
for inspection on-site.

i 7. Self -Monitoring Program
A review of DMRs from September, 2016 through September, 2017 showed only the following
violation, which was addressed through separate correspondence:
VIOLATIONDATE VIOLATION TYPE VIOLATION ACTION
07/17/2017 Aquatic toxicity permit limit violation Proceed to NOV
A comparison of submitted DMR data and field records showed no errors or concerns.
8. Laboratory
All parameters are analyzed by the City of Burlington Wastewater Treatment Plant Laboratory
under certification #188, except for headworks, toxicity and the effluent pollutant scan, which are
analyzed by Meritech under certification #165. When a separate lab analyzes headworks samples,
they also analyze all other samples collected that day. Operators of the plant analyze field
parameters under the City of Burlington WWTP Lab's certification. Copies of all laboratory
documentation are kept at the Burlington WWTP Lab.
Effluent composite sampler is flow proportional. The thermometer inside the sampler read 3°C at
the time of inspection, and the sampler produced a 150 ml aliquot. Composite samples are taken at
around 2 AM every morning, and grab samples are generally taken around 6 AM. Sampling and
field parameter measurement procedures appeared acceptable.
9. Sludge Handling Disposal
A small percentage of solids from the plant are treated at the compost facility on site. The residuals
are pressed and mixed to create the compost, which is sold on site. The remainder of the residuals
from the plant are land applied under permit WQ0000520.
If you should have any questions, please do not hesitate to contact Paul DiMatteo at [phone] or
our office at [phone].
Sincerely,
t-L/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: Rick Asher, by email
WQS Winston-Salem Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
Central Files

United States Environmental Protection Agency
Form Approved
EPA Washington, D C 20460
OMB No 2040-0057
Water Compliance Inspection Report
Approval expires B-31-98
Section A National Data System Coding (i.e, PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 E 2 151 3 I N00023876 I11 12 17/10/11 17 18 I r. I 19 I � j 201I
211 111 1 1 1 1 1 1 11 1 1 I I I I I I I I I I 1 1 I I I I I 1 1 1 1 11 1 1 1 1 1_J6
Inspection Work Days Facility Self-Monitonng Evaluation Rating 131 QA--------Reseryed
67 70 u 71 I I 72 N 73 I X74 75 IJJ80
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)
10 15A 17/10/11
14/07/01
Southside WWTP
Exit Time/Date
Permit Expirabon Date
2471 Boy Wood Rd
01 00p 17/10/11
19/06/30
Burlington NC 27215
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Richard Brian Asher/ORC/336-227-6261/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Robert C Patterson,PO Box 1358 Burlington NC
No
272161358//336-222-5130/3365706175
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 0 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/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
L �
44
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 NCO023876 I11 12 17/10/11 17 18 I e. 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 July 1, 2014 and expires on June 30, 2019. A copy of the
current permit was available for review Permitted components include a 3.5 million gallon aerated
equalization basin, primary and secondary clarifiers, biological nutrient reduction, sand filtration, and
gas chlorination.
2. Facility Site Review
The facility was as described in the permit. At the time of inspection, secondary clarifier #4 was down
for routine maintenance. It was noted during the previous inspection that the plant planned to replace
the gas chlorine disinfection system with liquid chlorine, however, Mr Asher said that the details had
not yet been finalized. The backup power generator is tested under lead for one hour every month. Mr
Asher said that if the generator's fuel tank is full it is capable of powering the entire plant for about 2
days.
3 Operation and Maintenance
Rick Asher is the current Operator in Responsible Charge, and Mark Andrews and Elizabeth Whitfield
are backup ORCs. All operators are properly designated and hold the correct credentials However, as
of the date of this letter Mr. Andrews has not received the required Continuing Education hours for
2017.
The operators use the Hach Water Information Management Systems (WIMS) database to track trends
in the treatment process and integrate reporting and documentation, and the Hach JOB Cal systemto
track all preventative and repair work at the plant.
4. Flow Measurement
Both influent and effluent flow meters are checked every 3 months and calibrated at least once per
year by Carolina Tech The meters were last calibrated in August, 2017 Only the effluent flow is
reported. For both influent and effluent flow measurement, a 2 foot Parshall flume is used as the
primary flow device, and an ultrasonic flow meter is used as the secondary device.
At the effluent, it appeared that the secondary device may not have been in the correct location for
accurately measuring flow To ensure sufficient accuracy of reported flow data, please.
a Verify that the secondary device is in the proper location and that the device and recorder are
accurate within 10% of the true flow value, and
b Submit a copy of the next effluent flow meter calibration check and any accompanying adjustments
made to the meter to this office for review
5 Effluent/Receiving Waters
The effluent is discharged to the Big Alamance Creek in the Cape Fear River Basin. In -stream
monitoring requirements have been waived as long as the City of Burlington remains a member of the
Upper Cape Fear River Basin Association.
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.
Please note that Permit Part I, Condition A(9) requires a mercury minimization plan to be developed no
later than January 1, 2015 and implemented during the permit term. A sample MMP was developed and
is available on the Division's website. During the inspection Mr. Asher was not able to produce a copy
of the sample MMP, but the facility's own plan was not available. Please ensure that a plan has been
developed and implemented, and keep a copy of the plan available for inspection on-site
7. Self -Monitoring Program
A review of DMRs from September, 2016 through September, 2017 showed only the following violation,
which was addressed through separate correspondence•
Page#

Permit: NCO023876
Inspection Date: 10/11/2017
Owner -Facility. SouthsideWWTP
Inspection Type Compliance Evaluation
VIOLATIONDATE VIOLATION TYPE VIOLATION ACTION
07/17/2017 Aquatic toxicity permit limit violation Proceed to NOV
A comparison of submitted DMR data and field records showed no errors or concerns
8. Laboratory
All parameters are analyzed by the City of Burlington Wastewater Treatment Plant Laboratory under
certification #188, except for headworks, toxicity and the effluent pollutant scan, which are analyzed by
Meritech under certification #165 When a separate lab analyzes headworks samples, they also
analyze all other samples collected that day Operators of the plant analyze field parameters under the
City of Burlington WWTP Lab's certification. Copies of all laboratory documentation are kept at the
Burlington WWTP Lab.
Effluent composite sampler is flow proportional. The thermometer inside the sampler read YC at the
time of inspection, and the sampler produced a 150 ml aliquot Composite samples are taken at
around 2 AM every morning, and grab samples are generally taken around 6 AM. Sampling and field
parameter measurement procedures appeared acceptable
9. Sludge Handling Disposal
A small percentage of solids from the plant are treated at the compost facility on site The residuals are
pressed and mixed to create the compost, which is sold on site The remainder of the residuals from
the plant are land applied under permit WQ0000520.
Page#

Permit NCO023876 Owner - Facility. Southside wwTP
Inspection Date- 10/11/2017 Inspection Type- Compliance Evaluation
V
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 0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment
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?
❑
❑
❑
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
M
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg required 5 years)?
0
❑
❑
❑
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?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
0
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
N
❑
❑
❑
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?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
M
❑
❑
❑
Page# 4

N
Permit, NCO023876
Inspection Date: 10/11/2017
Record Keeping
Facility has copy of previous year's Annual Report on file for review?
Owner -Facility: SouthsideWWTP
Inspection Type Compliance Evaluation
Yes No NA NE
■ ❑ ❑ ❑
Comment: Mr Asher said that almost all laboratory documents are sent to and kept bv_the City's Water
Resources lab.
Yes No NA NE
# Is flow meter used for reporting?
M
❑
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?
M
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
M
❑
❑
❑
Is flow meter calibrated annually?
N
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment- Both influent and effluent flow meters are checked about every 3 months and calibrated at
least once per year by Carolina Tech. Only the effluent flow is reported. Secondary effluent
flow device is a Siemens Milltronics OCM III. Primary flow device is a 2' Parshall flume.
It appeared that the secondary device may not have been in the correct location Please
verify that the secondary device is in the proper location and that the device and recorder are
accurate to within 10% of the true flow value.
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
M
❑
❑
❑
Is the basin free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
❑
❑
❑
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
❑
0
# Is basin size/volume adequate?
0
❑
❑
❑
Comment:
Primary 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 ❑ ❑ ❑
Page# 5

Permit NCO023876 Owner -Facility. Southside WWTP
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
N
❑
Inspection Date- 10/11/2017 Inspection Type Compliance Evaluation
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
M
❑
Primary Clarifier
Yes No NA NE
Are weirs level?
M
❑
❑
❑
Is the site free of weir blockage?
M
❑
❑
❑
Is the site free of evidence of short-circuiting?
M
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
M
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately '/a of the sidewall depth)
❑
❑
❑
M
Comment
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
N
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
M
❑
❑
❑
Are weirs level?
M
❑
❑
❑
Is the site free of weir blockage?
M
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
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 1/4 of the sidewall depth)
0
❑
❑
❑
Comment: Sludge blanket level was — 6 inches ORC said he tries to keep
it at this level because of a
possible premature release of phosphorus if the level is higher.
Clarifier #4 is out of service for maintenance.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Yes No NA NE
Ext Air
Diffused
M ❑ ❑ ❑
❑ ❑ ■ ❑
M ❑ ❑ ❑
■ ❑ ❑ ❑
M ❑ ❑ ❑
Page# 6
B

Permit NCO023876 Owner - Facility. Southside WwTP
Inspection Date. 10/11/2017 Inspection Type- Compliance Evaluation
Aeration Basins Yes No NA NE
Is the DO level acceptable? N ❑ ❑ ❑
Is the DO level acceptable?(1 0 to 3.0 mg/1) 0 ❑ ❑ ❑
Comment:
Nutrient Removal
Yes No NA NE
# Is total nitrogen removal required?
❑
❑
❑
❑
# Is total phosphorous removal required?
❑
❑
❑
❑
Type
N
❑
❑
❑
# Is chemical feed required to sustain process?
❑
❑
❑
❑
Is nutrient removal process operating properly?
❑
❑
❑
❑
Comment.
Disinfection -Gas
Yes No NA NE
Are cylinders secured adequately?
N
❑
❑
❑
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
N
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
E
Is the contact chamber free of growth, or sludge buildup?
E
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
0
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No 7782-50-5)?
❑
❑
❑
0
If yes, then is there a Risk Management Plan on site?
❑
❑
❑
0
If yes, then what is the EPA twelve digit ID Number? (10007
Ifyes, then when was the RMP last updated?
Comment.
Standby Power
Yes No NA NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
N
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
E
Do the generator(s) have adequate capacity to operate the entire wastewater site?
E
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
❑
Is the generator fuel level monitored?
❑
❑
❑
Page# 7

Permit- NCO023876
Inspection Date. 10/11/2017
Standby Power
Comment:
Owner - Facility Southside WWTP
Inspection Type. Compliance Evaluation
Laboratory
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?
M
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ❑ ■
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment Accordinq to their thermometers BOD Incubator was 19 5 C and fecal coliform Incubator
was 44.5 C at the time of Inspection.
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
❑
❑
❑
M
Is sample collected above side streams?
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
❑
❑
❑
Celsius)?
Is sampling performed according to the permit?
N
❑
❑
❑
Comment:
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
❑
Is sample collected below all treatment units?
❑
❑
❑
Is proper volume collected?
❑
❑
❑
N
Is the tubing clean?
M
❑
❑
❑
# 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)?
Comment:
Flow Measurement - Influent Yes No NA NE
Page# 8

9
Permit• NC0023876 Owner -Facility. SouthsideWWTP
Inspection Date- 10/11/2017 Inspection Type Compliance Evaluation
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
❑
M
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
N
❑
Comment Influent flow measuring primary device is a 24" Parshall flume with an ultrasonic secondary
device.
Page# 9