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Home My WebLink AboutNC0068888_Compliance Evaluation Inspection_20171027Water Resources ENVIRONMENTAL QUALITY CERTIFIED MAIL # 70151370 0000 2595 7283 RETURN RECEIPT REQUESTED October 27, 2017 Mr. Bill Trudnak, Public Works Director Town of Dallas 210 North Holland Street Dallas, NC 28034 ROY COOPER Govemor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director RECEIW-D/NCDF-0/ fiR OCT 3 0 2017 Water Quality Permitting Section Subject: Notice of Violation Compliance Evaluation Inspection NOV-2017-PC-0681 Dallas WWTP NPDES Permit No. NCO068888 Gaston County Dear Mr. Trudnak: Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at the subject facility on October 25, 2017 by Ori Tuvia and Maria Schutte. Brad Anthony's cooperation during the site visit was much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of the enclosed report. The following violations and/or areas of concern were observed during the inspection: 1) Chain of Custody and instrument calibration records for field parameters (pH, DO, chlorine and temperature) were not available for review during the inspection. Facility must have all data used for DMR reporting available for review. These records, or copies, shall be maintained for a period of at least three (3) years from the date of the sample, measurement, report or application. 2) Influent and effluent samplers were locked and not available for review at the time of the inspection. Inspectors must be able to inspect all wastewater units, sampling equipment and records. 3) The inspection revealed that regular process control sampling had been conducted at the effluent discharge outfall. All sampling conducted at the effluent discharge outfall must be analyzed by a certified lab and must be reported. Sampling for process control may be conducted in a location prior to the last treatment process. Alternatively, the facility may continue with process control sampling at the current location provided the analysis is conducted by a certified lab and the sampling results reported. Mooresville Regional Office Location, 610 East Center Ave, Suite 301 Mooresville, NC 28115 Phone (704) 663-16991 Fax: (704) 663.60401 Customer Service, 1-877-623-6748 4) At the time of the inspection, it was evident that the screening was not adequate with large debris passing through causing downstream treatment units to fail or improperly operate. Facility should investigate how to resolve the issue and improve screening capabilities. 5) Flow measurement devices were both overdue for calibration. Flow meters must be calibrated annually. 6) At the time of the inspection, the drying beds were overgrown with vegetation. Drying beds must be properly maintained. Please be advised that this letter is a Notice of Violation. You are requested to respond to this Notice in writing within fifteen (15) days of receipt indicating your Plan of Action to resolve the non-compliance issues. This Plan of Action should include a timeline within which the items till be adequately addressed. Failure to respond and/or failure to resolve the violations could subject you for further action by the Division of Water Resources. Please be advised that pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per day, per violation and may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at ori.tuvia@ncdenr.gov. Sincerely, W. Corey Basinger Regional Supervisor Mooresville Regional Office Division of Water Resources Cc: Brad Anthony (E -copy) NPDES Unit MRO Files +4 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 IN 1 2 15 I 3 I N00068888 I11 12 17/10/25 17 18 I r. I 19 I c I 20I 21111111 111111111111111111 1111111 IIIIIII II I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -----Reserved---- 67 --- Reserved-- - 67 10 70 Iz I 71 ty�ti � 72 LJ I I I �i 731 I 174 75 80 LJ Section B• Facility .lData Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 09 55AM 17/10/25 15/02/01 Dallas WWTP Exit Time/D'ate Permit Expiration Date 704 E Holly St 12 30PM 17/10/25 20/01/31 Dallas NC 28034 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Bradley Gene Anthony/ORC/704-214-69881 Name, Address of Responsible Ofricialf title/Phone and Fax Number Contacted James M Palenick,210 N Holland St Dallas NC 280342749/Interim Town No Manager/704-922-3176/7049224701 Section C Areas Evaluated During Inspection (Check only those areas evaluated) Permit N Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program N 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 Maria Schutte Division of Water Quality//704-663-1699i On A Tuvia MRO W0//704-663-1699/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger MRO WQ//704-235-2194/ Z A For 60-3 (Re 9-94) Previous editions are obsolete ' ezcz Page# NPDES yr/mo/day Inspection Type 1 31 NCO068888 I11 12I 17/10/25 I17 18 ICI _J Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) a Page# 2 Permit NCO068888 Owner -Facility DallasWWTP Inspection Date 10/25/2017 Inspection Type Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less) Has the permittee submitted a new ❑ ❑ 0 ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ Is all required information readily available, complete and current? ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? M ❑ ❑ ❑ Comment- The subject permit expires on 1/31/2020. ❑ Is the chain -of -custody complete? 0 ❑ 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? ❑ 0 ❑ ❑ 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 0 ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 Name of individual performing the sampling M Results of analysis and calibration ❑ Dates of analysis Has the facility submitted Its annual compliance report to users and DWQ? Name of person performing analyses ❑ Transported COCs ❑ Are DMRs complete- do they include all permit parameters? M ❑ ❑ ❑ 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 ❑ ❑ M ❑ 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? M ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ 0 Comment: DMRs. COCs. ORC visitation logs and calibration logs were reviewed for the period October 2016 through May 2017. Chain of Custody and instrument calibration records for field parameters (pH DO chlorine and temperature) were not available for review during the inspection Facility must have all data used for DMR reporting available for review. These records or copies shall be maintained for a period of at least three (3) years from the date of the sample measurement, report or application Page# 3 Permit NCO068888 Owner -Facility DaiIasWWTP Inspection Date 10/25/2017 Inspection Type Compliance Evaluation Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 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? M ❑ ❑ ❑ # 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 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/-1 0 degrees? ❑ ❑ M ❑ Comment: nfluent, effluent (Including field parameters), and upstream/downstream analyses are berformed under the City of Gastonia Crowders Creek Laboratory Certification #210. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (keot at less than or equal to 6 0 degrees Celsius)? Is sampling performed according to the permit? Yes No NA NE ❑ ❑ M ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ■ ❑ ❑ ❑ Comment: Influent sampler was locked and not available for review at the time of the inspection Inspectors must be able to inspect all wastewater units, sampling equipment and records. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? M ❑ ❑ ❑ Is proper volume collected? ❑ ❑ 0 ❑ Is the tubing clean? n ❑ ❑ ■ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees ❑ ❑ 0 ❑ Celsius)? I Is the facility sampling performed as required by the permit (frequency, sampling type M ❑ ❑ ❑ representative)? Comment effluent samDler was locked and not available for review at the time of the Inspection. Inspectors must be able to inspect all wastewater units, sampling equipment and records. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ ❑ sampling location)? Page# 4 r ' Permit NC0068868 Owner -Facility Dallas WWTP Inspection Date 10/2512017 Inspection Type Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Comment. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable N ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The insDection revealed that reaular process control samplinq had been conducted at the effluent discharge outfall. All sampling conducted at the effluent discharge outfall must be analyzed by a certified lab and must be reported. Sampling for process control may be conducted in a location prior to the last treatment Process Alternatively, the facility may continue with process control sampling at the current location provided the analysis is conducted by a certified lab and the sampling results reported. Bar Screens Yes No NA NE Type of bar screen Is the basin free of dead spots? 0 ❑ a Manual ❑ Are surface aerators and mixers operational? ❑ ❑ b Mechanical ❑ Are the diffusers operational? 0 ❑ 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: At the time of the insDection, it was evident_ that the screening was not adequate with large debris passing through causing downstream treatment units to fail or improperly operate. Facility should investigate how to resolve the issue and improve screening capabilities. 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? ❑ ❑ E ❑ 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? M ❑ ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1 0 to 3 0 mg/1) E ❑ ❑ ❑ Comment. Page# 5 Permit NCO068888 Owner -Facility DaIIaSWWTP Are cylinders secured adequately? 0 ❑ Inspection Date 10/25/2017 Inspection Type Compliance Evaluation Are cylinders protected from direct sunlight? Gas ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? ❑ ❑ 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? E ❑ ❑ ❑ Are weirs level? E ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? ❑ ❑ ❑ Is the site free of excessive floating sludge? ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? E ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) E ❑ ❑ ❑ Comment: At the time of the inspection the facillity was in the process of pumping excess sludge from the chlorine contact chamber. Excess sludge was due to faliure of scraper arm of one of the clarriers. Disinfection -Gas Yes No NA NE Are cylinders secured adequately? 0 ❑ ❑ ❑ Are cylinders protected from direct sunlight? Gas ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? ❑ ❑ ❑ ❑ Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? E ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? E ❑ ❑ ❑ 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? ❑ ❑ E ❑ If yes, then what is the EPA twelve digit ID Number? (10007 If yes, then when was the RMP last updated? Comment: The chlorination and dechlorination systems are serviced annually by a contracted company. De -chlorination Yes No NA NE Type of system ? Gas Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ E Is storage appropriate for cylinders? 0 ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ 0 ❑ ❑ Page# 6 Permit NCO068888 Inspection Date 10/25/2017 De -chlorination Are the tablets the proper size and type? Owner -Facility Dallas WWTP Inspection Type Compliance Evaluation Yes No NA NE ❑ ❑ M ❑ Comment: The chlorination and dechlorination systems are stored and operated in the same building. Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? Comment. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? M ❑ ❑ ❑ Is flow meter calibrated annually? ❑ 0 ❑ ❑ Is the flow meter operational? ❑ ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 110 if effluent (diffuser pipes are required) are they operating properly? Comment: The flow meters at each treatment train are connected to a totalizing system (with chart recording). Both flow meters and totalizing system were overdue for calibration, last Yes No NA NE Is the capacity adequate? 0 calibrated on 7/28/2016 by Ken Nash Co. ❑ ❑ Is the mixing adequate? 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: The effluent appeared clear with no floatable solids or foam. Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? M ❑ ❑ ❑ Is the site free of excessive foaming in the tank? ❑ ❑ ❑ ❑ # Is the odor acceptable? ❑ ❑ ❑ ❑ # Is tankage available for properly waste sludge? M ❑ ❑ ❑ Comment: Each treatment train Is equipped with an aerobic diqester The bio -solids in the aerobic digesters are land applied under permit number WQ0020912 by a contracted company. Southern Soil Builders. Drying Beds ' Yes No NA NE Is there adequate drying bed space? ❑ ❑ M ❑ Is the sludge distribution on drying beds appropriate? ❑ ❑ 0 ❑ Are the drying beds free of vegetation? ❑ M ❑ ❑ Page# 7 Permit NCO068888 Owner -Facility Dallas WWTP Inspection Date 10/25/2017 Inspection Type Compliance Evaluation Drying Beds Yes No NA NE # Is the site free of dry sludge remaining In beds? ❑ ❑ N ❑ Is the site free of stockpiled sludge? 0 ❑ ❑ ❑ Is the filtrate from sludge drying beds returned to the front of the plant? ❑ ❑ ❑ 0 # Is the sludge disposed of through county landfill? 0 ❑ ❑ ❑ # Is the sludge land applied? M ❑ ❑ ❑ (Vacuum filters) Is polymer mixing adequate? ❑ ❑ 0 ❑ Comment: The bio -solids in the aerobic digesters are land applied under permit number WQ0020912 by a contracted company. Southern Soil Builders At the time of the inspection the drying beds were overgrown with vegetation. Drying beds must be properly maintained. Page# 8