The URL can be used to link to this page

Home My WebLink AboutNC0025321_Compliance Evaluation Inspection_20180904 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Certified Mail #7017 2620 0000 9759 5718 Return Receipt Requested September 4, 2018 Gavin A Brown Town of Waynesville PO Box 100 Waynesville, NC 28786 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2018-PC-0360 Permit No. NC0025321 Waynesville WWTP Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Waynesville WWTP on August 21, 2018. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0025321. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Permit Identified interfering discharges have not been addressed by the town as required by Part IV Special Conditions for Municipal Facilities. _________________________________________________________________________________________________________________________________________________________________________ Operations & Maintenance Treatment components are reaching the end of their life expectancy and are no longer fully operational. Facility no longer appears capable of adequately treating incoming wastewater. A finalized decision, regarding WWTP upgrades, has not been conveyed or presented to DWR. Part II Standard Conditions Section C(2) The Permittee shall at all times properly operate and maintain all facilities and systems of treatment control which are installed or used by the Permittee to achieve compliance with the conditions of this permit. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Please reference the enclosed inspection report for specific examples. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identif ied issues, if applicable. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828 -296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report EC: WQS-ARO Server LF David Foster- Director Public Works Preston Gregg, PE- Town Engineer Ronnie Norris, ORC 20180904_NC0025321_NOV2018PC0360 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0025321 18/08/21 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Waynesville WWTP 300 Walnut Trl Waynesville NC 28786 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 18/08/21 17/03/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Mark Allen Jones/ORC/828-452-4685/ Ronnie D Norris/ORC/828-452-4685/ Other Facility Data 11:30AM 18/08/21 21/01/31 Name, Address of Responsible Official/Title/Phone and Fax Number David Foster,PO Box 100 Waynesville NC 28786/Public Services Director/828-456-3706/8284562000 Contacted 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 Pretreatment 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 Timothy H Heim ARO WQ//828-296-4665/ Mikal Willmer Division of Water Quality//828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 8/30/2018 8/31/2018 8/31/2018 NPDES yr/mo/day 18/08/21 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Inspectors Mikal Willmer and Tim Heim, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Waynesville WWTP on August 21, 2018. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0025321. ORC Ronnie Norris and Backup ORC Mark Jones were present and assisted in the inspection. Many of the treatment units are reaching the end of their useable life expectancy and potential external contributions to the collection system waste stream have made maintaining healthy biota and optimal operating conditions within the facility difficult. The facility continually struggles to meet permit limits for TSS and NH3. Below is a listing of items documented during the inspection: Wastestream Influence: Matrix Interferences were noted during NH3 testing last year. Salts are precipitating out of solution at elevated pHs. Collection System sampling indicated significant changes in sulfates, conductivity, Total Solids, Hardness and Alkalinity levels above and below Giles Chemical's (Epson Salt Manufacturer) discharge into the collection system. Drastic changes to basin conditions can cause die off beneficial organisms within the facility and allow proliferation of non-target organisms. Headworks: Staff report the headworks struggles to handle heavy flows into the facility. Additionally, the mechanical bar screen is not connected to the generator, therefore staff must manually open and close gates and monitor the manual bypass screen (continuous raking) during power outages. This is a safety hazard and requires more staff resources during outages. Structural: Noted several areas where leaks are occurring around piping entering and exiting concrete basins. Facility staff stated a firm is scheduled to come repair known spalling concrete and leaks throughout the facility within the next week. Basins: Several of the concrete catwalks have significant spalling. Metal railings are loose from walkways in several locations, creating a potential fall hazard. Diffusers are missing and facility staff cannot remove several of the diffusers without a crane. One basin is being used solely as an aerobic digester. Several of the basins have filamentous bacteria floating on the surface and DO levels are reported to be <1 mg/L in the basins. RAS/WAS: Staff still have no means of controlling the return and wasting rate. This was noted in the previous inspection. This significantly limits the operators' ability to maintain an appropriate sludge blanket and sludge age within the facility. Clarifiers: Significant floating solids within the clarifiers. Retention time does not appear adequate. Trac Vac system does not operate as intended. Staff report issues maintaining the system. Staff must walk on the trac system to clean lines, presenting another trip/fall hazard. Chlorine Contact Chamber: Staff indicated the chamber is pumped down and cleaned weekly; however, solids are still present in significant amounts. Solids Handling: Staff report solids storage is inadequate. The two thickeners and one anaerobic digester are undersized for the size of facility. One AB has been converted to an aerobic digester to help better manage solids. The thickeners are being rerouted to the headworks at times to accommodate the need for solids wasting and processing. I&I: The treatment works sees 2 MG flow swings during heavy rain events, often peaking above design NC0025321 17 (Cont.) Page#2 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation flow for several days. Inspectors do acknowledge the Town has budgeted more for maintenance of the facility this fiscal year and that the $200k allotted is being used to repair diffusers and repair failing concrete. ARO is also aware and acknowledges that McGill has completed an engineering assessment and presented to the Board; however, a finalized decision in regard to the future plans for the WWTP has not been conveyed to DWR. In addition to planned plant upgrades, the Town will need to assess potential negative impacts on the facility from the Collection System. As stated above, I&I is introducing, at a minimum, a million gallons of flow to the system, which has the potential to hydraulically overload the facility. Industrial discharges into the system also need to be assessed by the Town. Waynesville is no longer under a DWR approved pretreatment program; however, discharges into the collection system that may negatively impact the Town's ability to adequately treat incoming wastewater and maintain compliance should be addressed. Page#3 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Monitor DO, pH, solids and additional parameters as needed.Comment: 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? # 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? Standard Effluent Toxicity, MMP and Pollutants Scan.Comment: 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)? 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? Has the facility submitted its annual compliance report to users and DWQ? (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? 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? Is a copy of the current NPDES permit available on site? Page#4 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? All files are maintained onsite in the main building.Comment: Flow Measurement - Influent Yes No NA NE # 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? Facility records and reports influent flow readings for daily/monthly flow.Comment: Influent Sampling Yes No NA NE # 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 (kept at less than or equal to 6.0 degrees Celsius)? Is sampling performed according to the permit? Sample for influent BOD, TSS, NH3Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual b.Mechanical Is the grit free of excessive organic matter? Is the grit free of excessive odor? # Is disposal of grit in compliance? airlift pumps remove grit from chamber.Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Page#5 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Bar Screens Yes No NA NE Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Mechanical bar screen is in need of repair or replacement. Some of the chain guards are in need of repair/replacement. Allows some pass through of debris. Mechanical screen is not connected to the generator. Facility staff have to continuously rake the manual bypass bar screen during power outages. Comment: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? 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? Is the sludge blanket level acceptable? Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth) all sludge is wasted from primary clarifiers.Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused 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? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/l) Page#6 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Aeration Basins Yes No NA NE One of the basins is being used as an aerobic digester due to inadequate solids storage. Plant staff state they operate the facility on two of the basins; however, these are not operating optimally. There are dead spots within the basin and several diffusers are missing. Filamentous bacteria are prevalent in the basin and the DO level at the time of the inspection was 0.82 mg/L. Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? 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? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth) Rectangular clarifiers with evidence of short-circuting and uneven flow distribution over weirs. Trac-VAC system does not operate optimally. Operators have to climb on to Trac systems to wash out lines. Floating sludge is visible throughout both clarifiers indicating issues with the sludge blanket and settling. Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? All pumps are in place and operable; however, facility staff have no way to regulate the RAS/WAS rate. This severely limits solids handling within the facility. Comment: Anaerobic Digester Yes No NA NE Type of operation:Floating cover Is the capacity adequate? # Is gas stored on site? Is the digester(s) free of tilting covers? Is the gas burner operational? Is the digester heated? Page#7 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Anaerobic Digester Yes No NA NE Is the temperature maintained constantly? Is tankage available for properly waste sludge? According to plant staff the thickeners are undersized and the digester is about half the size needed. Comment: Solids Handling Equipment Yes No NA NE Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Filter press and lime stabilization equipment is in need of repair/replacement in the near future. Class A Residuals storage may need to be increased if it is not being hauled regularly to customers or to the landfill. Currently any runoff drains to the head of the plant. Comment: Disinfection-Gas Yes No NA NE Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de-chlorination? Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000-____-____) If yes, then when was the RMP last updated? Chlorine contact chamber is being drained and cleaned once a week; however, there are still significant solids floating on the surface of the contact chamber. Facility projected upgrade would replace gas disinfection with liquid chlorine. Comment: De-chlorination Yes No NA NE Type of system ?Gas Is the feed ratio proportional to chlorine amount (1 to 1)? Page#8 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation De-chlorination Yes No NA NE Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? Facility projected upgrade would replace gas dechlorination with liquid.Comment: Laboratory Yes No NA NE 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? All data is kept within the laboratory separated by parameter.Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # 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: Effluent Pipe Yes No NA NE 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? Did not visit effluent final discharge to Pigeon River.Comment: Page#9 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36 Permit:NC0025321 Inspection Date:08/21/2018 Owner - Facility: Inspection Type: Waynesville WWTP Compliance Evaluation Effluent Pipe Yes No NA NE Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Bar screen is not connected, manual bypass screen has to be used during power outages.Comment: Page#10 DocuSign Envelope ID: 441CE387-1394-4A31-8D04-CC505BB8BF36