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HomeMy WebLinkAboutNC0006190_NOV2018PC0081_20180318Water Resources ^ Environmental Quality 8 March 2018 CERTIFIED MAIL #: 7016 1370 0000 2595 8006 RETURN RECEIPT REQUESTED Mr. Everette Owens South Fork Industries, Inc. PO Box 742 Maiden, North Carolina 28650 Subject: Dear Mr. Owens: ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Notice of Violation Compliance Evaluation Inspection South Fork Industries, Inc. W WTP NPDES Permit No. NC0006190 Catawba County Tracking #: NOV-2018-PC-0081 Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on February 22, 2018, by Mr. Wes Bell of this Office. Please inform the facility's Operator - in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the following: 1. Failure to monitor the influent, upstream and downstream during the weeks of November 19, 2017 and December 24, 2017; 2. Failure to report a bypass (clarifier) during the first week of January 2018; and, 3. Failure to conduct visitation at the subject facility by either the designated ORC or Backup ORC on two days during the week of December 24, 2017. These are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Record Keeping/Summary and Secondary Clarifier/Summary Sections of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day 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. State of North Carolina I Environmental Quality] Water Resources I Water Quality Regional Operations Mooresville Regional Office 1 610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115 704-663-1699 Mr. Everette Owens Page Two March 8, 2018 It is requested that a written response be submitted to this Office by March 29, 2018, detailing the actions taken to address all above -noted violations and the deficiencies noted in the Influent Sampling, Laboratory/Summary, Operation & Maintenance/Summary, Bar Screens, Aeration Basin, and Aerobic Digester Sections in this report. br responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192, or via email at wes.bellna,ncdenr.gov. Sincerely, MW 047..'A MI) FRO W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosures: Inspection Report Photos 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 IS I 3 I NC0006190 I11 12 ' 18/02/22 17 181r.1 191 G I 201 I 21IIIIII IIIIII11 111IIIIIII1IIIIII IIIIIIlUl26 Inspection Work Days Facility Self -Monitoring Evaluation Rating 31 QA ----------------Reserved------------ 1 72 1 ., 1 731 1 174 75I I I I I I I I80 67 z.0 701, I 71 it1.� L LJ J I I I Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Dale Permit Effective Date POTW name and NPDES permit Number) 09 15A 18/02/22 13/05/01 South Fork Industries - Maiden Plant 100 W Pine St Exit Time/Date Permit Expiration Date Maiden NO 28650 03:OOPM 18/02/22 16/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// J Wayne Kelly/ORC/828-428-9921/ Name, Address of Responsible OfLial/rllle/Phone and Fax Number Contacted Everette J Owens,PO Box 742 Maiden NO 28650/Owner/828-428-9921/ 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 Insp///eQQctor(s) Agency/Office/Phone and Fax Numbers Date Wes Bell V MRO WQ//704-663-1699 Ext.2192/ W �3 /9///� Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger MRO WQH704-235-2194/ EPA For /80,-�3 (Rev 944) Previous editions are obsolete. Page# 1 NPDES ydnno/day Inspection Type (Cont,) 31 NC0006190 I11 12I 18/02/22 I17 18 1-1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On-site Representatives: The following South Fork Industries, Inc. personnel were in attendance during the inspection: Mr. Wayne Kelly/ORC; Mr. Allen Lynch/Backup ORC; and Mr. Britt Hewitt/Operator. RECORD KEEPING SECTION cont'd: A review of the self-monitoring data during the review period revealed the following: - No influent, effluent, upstream and downstream monitoring was performed during the weeks of 11/19/17 — 11/25/17 and 12/24/17 - 12/30/17. - No monitoring for effluent total nitrogen and total phosphorus (monthly) was performed in December 2017. - No monitoring for effluent chloride, sulfates, copper and zinc (quarterly) was performed in December 2017. Note: The effluent monitoring violations in November 2017 have been previously addressed by the Division through the issuance of a NOV. The influent, upstream, and downstream monitoring violations in November and December 2017 will be addressed in this inspection report. The December 2017 effluent monitoring violations will be separately addressed by the Division through the issuance of either a NOV or NOV/civil penalty assessment. Multiple revisions were made to the November and December 2017 eDMRs as a result of the inspection due to transcription errors including effluent flows not being correctly reported, effluent values being reported as "0" on non -sampling days, etc. The permittee and ORC must ensure all monitoring reports are properly completed prior to submittal. The wastewater treatment plant has been classified a Class III Biological Water Pollution Control Treatment System by the Water Pollution Control System Operators Certification Commission. The WWTP was not visited by either the designated ORC or Backup ORC on two days during the week of 12/24/17. Please be advised Class III Biological Water Pollution Control Treatment Systems are required to be visited by either the designated ORC or Backup ORC five days per week, excluding holidays [Reference: 15A NCAC 08G .0204 and NPDES Permit Part II, Section C (1) Certified Operator]. LABORATORY SECTION cont'd: The dissolved oxygen meter (Insite IG Model 3100) was not being properly verified against a standardized chart in accordance with the NC Wastewater Laboratory Certification Technical Guidance Document — Approved Procedure for the Analysis of Dissolved Oxygen. The pH buffers were being reused for the daily calibrations prior to effluent analyses. Please be advised that the pH buffer solutions used during the calibration process should not be used for more than one calibration and properly discarded. In addition, a check standard buffer was not being analyzed following the pH meter's calibration. The pH meter must read the check standard buffer within +/-0.1 S.U. (Reference: INC Wastewater Laboratory Certification Technical Guidance Document — Approved Procedure for the Analysis of pH). The facility staff must ensure that all effluent pH samples are collected and analyzed within 15 -minutes (Reference: 40 CFR 136.3 Table II). Influept and effluent samples are temporarily stored in a refrigerator prior to pick-up and shipment to the Page# 2 Permit NC0006190 Inspection Dale: 02/22/2018 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation contracted laboratory. The refrigerator's temperature was not being measured and/or documented for every day the unit was used for sample storage to verify the samples were being properly preserved at less than or equal to six degrees Celsius (Reference: 40 CFR 136.3 Table ll). OPERATION & MAINTENANCE SECTION cont'd: Facility staff indicated that a knitting oil had been previously disposed into the influent. Although this practice has ceased, any residual oil observed in the treatment facility (aeration basin, clarifiers, etc.) must be removed and properly disposed. An above ground storage tank (petroleum) had been placed on top of the grating at the influent screening building. The concrete conveyance system underneath the grating discharges directly into the wastewater treatment plant's (WWTP) influent. The above ground storage tank must be immediately removed and properly relocated to prevent any petroleum discharges from entering the influent waste stream of the WWTP. The facility staff must ensure that any residual solids adjacent to the concrete walls of aeration basin #2(from aeration basin foam going over the walls) are removed and properly disposed. A significant vertical crack was observed in the secondary containment structure for the peroxide and salt storage tanks. The crack should be properly repaired to ensure all leakages, spills, etc, are properly contained and not discharged into Waters of the State via stormwater drainage system. Note: The crack in the secondary containment structure was noted in the previous inspection report (dated 4/26/16). SECONDARY CLARIFIER SECTION cont'd: DWR staff was informed that a clarifier was bypassed during the first week of January 2018 that contributed to the facility being in noncompliance with effluent permit limits. No notification (verbal or written) was submitted to the Division as required by the NPDES Permit [Permit Condition Reference: Part Il, Section C(4) Bypassing of Treatment Facilities and Section E(6)Twenty-four Hour Reporting]. Page# Permit: NC0006190 Inspection Date: 02/22/2016 Permit Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation (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? Comment: The Division received the permit renewal Dackaae on 11/5/15 Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ The Division issued a minor permit modification on 12/1/2016 regarding a name/ownership change to South Fork Industries, Inc. The last compliance evaluation inspection was performed at the facility on 4/4/16 by DWR staff. 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? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Dates, times and location of sampling Monitoring Reports were reviewed for the period January 2017 through December 2017. No Name of individual performing the sampling effluent limit violations were reported. See "Summary" Section for additional comments. 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 ❑ ❑ 0 ❑ 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? 0 ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? N ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports were reviewed for the period January 2017 through December 2017. No effluent limit violations were reported. See "Summary" Section for additional comments. Page# 4 Permit: NC0006190 Inspection Date: 02/22/2016 Record Keeping Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation 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? N ❑ ❑ ❑ # 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 ❑ ❑ 0 ❑ Celsius)? 0 ❑ ❑ ❑ Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ N ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: On-site field analyses (dissolved oxygen pH temperature) are being performed under the facility's field laboratory certification #5302 R&A Labs has been contracted to provide analytical support. See "Summary" Section for additional comments. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ❑ E ❑ Is sample collected above side streams? M ❑ ❑ ❑ Is proper volume collected? N ❑ ❑ ❑ Is the tubing clean? ❑ E ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: The subiect permit requires influent composite color samples The facility has been granted a variance to perform time -based composite samples The sampler collected several hundred mis more than the programmed amount during the inspection In addition influent sampling was being performed in one of two influent channels that may differ in color pending on the production process The facility staff must ensure the sampler is properly operated and maintained at all times and representative influent samples are being collected. This Office recommends the replacement of the thermometers inside the influent and effluent samplers. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ Page# 5 Permit: NC0006190 Owner- Facility: South Fork Industries - Maiden Plant Inspection Date: 02/22/2018 Inspection Type: Compliance Evaluation Yes No NA NE Type of bar screen Effluent Sampling Yes No NA NE # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? b.Mechanical Is the facility sampling performed as required by the permit (frequency, sampling type E ❑ ❑ ❑ representative)? 0 ❑ ❑ Comment: The subject permit requires composite and grab effluent samples. The ORC and staff should perform and document (recommend monthly) periodic aliquot verifications on the influent and effluent samplers to ensure the proper aliquot volumes (100 mis. minimum) are being collected. The facility staff must ensure that the preset gallon interval between the collection of aliquots is fixed at no greater than 1/24 of the expected total daily flow at the treatment system [NPDES Permit Condition Reference: Part ll. Section A Definitions — Composite Sample Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? E ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable E ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Process control measurements were being properly documented and maintained on-site. Operation and maintenance (O&M) issues were noted during the inspection. These O&M issues are discussed further in the O&M/Summary Bar Screens Aeration Basin Secondary Clarifier/Summaryand Aerobic Digester Sections. Please be advised that the NPDES Permit requires the permittee to properly operated and maintain the facility at all times [Permit Condition: Part ll. Section C(2) Proper Operation and Maintenancel. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? ❑ N ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Page# 6 Perrnit. NC0006190 Inspection Date: 02/22/2018 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: compliance Evaluation Bar Screens Yes No NA NE Comment: The influent passes through one of three fine screens (shakers) for lint removal. The facility is also equipped with manual coarse screens prior to the aeration basin. Screenings are disposed at the County Landfill. All of the removed lint was not being disposed into the dumpster. Lint was observed on the ground/concrete and adjacent to the dumpster and stormdrain. All lint on the around/concrete must be removed and properly disposed. Aeration Basins Yes No NA NE Mode of operation E ❑ ❑ ❑ 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 far the treatment process? ❑ ❑ N ❑ Does the foam cover less than 25% of the basin's surface? ❑ 0 ❑ ❑ Is the DO level acceptable? ❑ 0 ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ 0 ❑ Comment: The facility is equipped with two aeration basins (1.25 MG each). Each aeration basin is equipped with three surface aerators. Microbial supplements are added daily to the aeration basins. The surface of aeration basin #2 was comDletely covered with a thick foam. however, no foam carryover was observed in the clarifier. The contents in aeration basin #1 were not being properly mixed and aerated due to two inoperable aerators. Facility staff indicated that new motors. etc. have been ordered and may take several weeks to receive the new equipment. Chemical Feed Yes No NA NE Is containment adequate? E ❑ ❑ ❑ Is storage adequate? 0 ❑ ❑ ❑ Are backup pumps available? N ❑ ❑ ❑ Is the site free of excessive leaking? 0 ❑ ❑ ❑ Comment: Both of the 3500 gallon flocculant tanks (one tank per aeration basin) and the polymer tote bin/mixing tank were operational and in service. 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? 0 ❑ ❑ ❑ Are weirs level? ❑ E ❑ ❑ Page# 7 Permit: NC0006190 Inspection Date: 02/22/2018 Secondary Clarifier Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin Floc? Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Both secondary clarifiers were operational and in service. Polvmer and flocculant are added to the clarifier influent to enhance the removal of color/suspended solids. The weirs were not level: however, no short-circuiting was observed. The clarifier effluent flows into an 84.000 gallon post aeration basin (surface aeration) prior to entering the effluent flow measurement/sampling location. See'Summarv" Section for additional comments. Pumps -RAS -WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? N ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ ❑ 0 Comment: 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: The flow meter is calibrated twice Der vear and was last calibrated on 2/21/18 b Clearwater. Inc. Facility staff should verify the time period that the flows are being totalized (ex. 12 a.m. to 12 a.m. or 7 a.m. to 7 a.m.) and ensure these flows are Properly reported on the monitoring reports (eDMR). Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? N ❑ ❑ ❑ 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 ❑ Page# 8 Perri(: NC0006190 Owner - Facility: South Fork Industries - Maiden Plant Inspection Date: 02/22/2018 Inspection Type: Compliance Evaluation Effluent Pipe Yes No NA NE Comment. The effluent appeared light purple with trace suspended solids and no foam. The receiving stream did not appear to be negatively impacted. Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? ❑ ❑ 0 ❑ Is the site free of excessive foaming in the tank? M ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: The 1.8 MG lagoon is equipped with surface aeration (2 -aerators total) however, one of the aerators was in the process of being repaired/replaced. No bio -solids have been removed from lagoon since the change in ownership. Svnagro has been contracted to land apply the bio -solids under the authority of Permit No. WQ0006984. Page# 9 RM �.� Eit i s VVV 7 �r 1 K� f Y F cn, t y' 'a Lint on the concrete adjacent to dumpster and stormwater drain and the petroleum tank being stored on top of the influent grating system. A significant vertical crack in the secondary containment structure.