NC0045292_Compliance Evaluation Inspection_20180910

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Interim Director September 10, 2018 RECEIVED/DENR/DWR
Mr. Victor Ray Quick SEP 2 5 2018
City of Graham
Water Resources
P.O. Drawer 357
Permitting Section
Graham, NC 27253-0357
SUBJECT: Compliance Evaluation Inspection Report
Graham-Mebane Water Treatment Plant
NPDES Permit No. NC0045292
Alamance County
•
Dear Mr. Quick:
•
On August 22, 2018, Paul DiMatteo of this office met with James Aiken, operator in responsible charge
(ORC), and Tonya Mann, backup ORC, to perform a Compliance Evaluation Inspection on the subject
wastewater treatment facility. A follow up inspection was conducted on September 6, 2018. This type of
inspection consists of two basic parts: an in-office file review and an on-site inspection of the treatment facility.
The attached inspection form notes the areas that were evaluated for this inspection. The findings and
observations are outlined as follows.
I. Permit
The permit became effective on July 1, 2017 and will expire on June 30, 2022. A copy of the current
permit was available during the inspection. The facility was as described in the permit.
II. Self-Monitoring Program
A review of discharge monitoring reports (DMRs)from May 2015 through June 2018 showed no actioned
violations. Effluent grab samples are taken at 3rd and final lagoon immediately prior to discharge. The permit
does not currently require composite sampling.
The facility measures temperature, pH and chlorine on-site, and other parameters except toxicity are
analyzed by the City of Graham VWVTP Laboratory under its certification,#240. Toxicity is analyzed by Meritech,
Inc., certification # 165. Calibration procedures for field parameters appeared acceptable.
III. Records/Reports
Copies of DMRs, operator visitation logs, daily operation sheets, maintenance reports, lab reports and
chain-of-custody forms were available for review during the inspection. DMRs and lab data are maintained
according to the permit. DMRs include all permit parameters. A comparison of submitted data with bench sheets
revealed no errors or concerns.
£D_E 0 )
NORTH CARCUNA f
DeNNPoomtot6lra th(Nab
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103
336.776.9800

Graham/Mebane WTP, 8/22/2018 '
IV. Flow Measurement
The newly renewed permit added a requirement for continuous flow measuring and allowed up to 18
months to install a continuous flow meter. The facility received proposals and installed a series of sensors and
accompanying electrical equipment to the existing flow control gate structure in the 3rd and final lagoon as
proposed by their engineer, as this was seen as the most economically preferable option. An Authorization to
Construct (AtoC) is not required by this office for water treatment plants, and the Public Water Supply section
commented that they would not have required an AtoC either as the installation did not alter the capacity or
treatment process of the plant. As such, this flow monitoring method was installed without prior Division review.
It should be noted that, although an AtoC was not required for this installation, Part II, Section D.3 of the
Permit requires that "The Director shall approve the flow measurement device and monitoring location prior to
installation." This Condition also requires that "Appropriate flow measurement devices and methods consistent
with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of
measurements of the volume of monitored discharges."
This office offers comments regarding the information obtained in support of the chosen flow monitoring
method as follows. These comments are based in part on the NCDEQ Adapted NPDES Inspection Manual,
Section 6, Flow Measurement, and Appendix 0, Supplemental Flow Measurement Information (this chapter is
adopted with minor modifications based on the US Environmental Protection Agency's Interim NPDES Inspection
Manual revised 2017), the US Department of the Interior's Water Measurement Manual revised 2001, and the
ISCO Open Channel Flow Measurement Manual. We request that you provide a response to these comments
indicating why the structure will still be accurate to within 10% of the actual flow within 30 days of receipt of this
letter.
1. The discharge equation provided appears to classify the structure as a 4-foot-wide contracted rectangular
weir.
2. The flow control gate structure does not span the entire channel.
3. The weir crest appeared to be 1/4 inch thick with no chamfer. The edge of the weir crest should be no
more than 1/8 inch thick.
4. The weir crest was not uniform throughout the crest's span. The gate's control mechanism extends
vertically into the crest.
5. Debris accumulation was present on the weir crest and gate control mechanism.
6. The upstream face of the weir plate was not smooth and was not in one plane.
7. The weir crest must be kept level.
8. The nappe did not appear to spring free from all portions of the weir crest.
9. During the follow up inspection, SCADA reported that the peak, average, and minimum flows for the
previous 24 hour period were 1,247, 145, and 12.7 gallons per minute, respectively. These correspond
to head heights of approximately 0.356, 0.084, and 0.017 feet, respectively, with peak flows typically
occurring during filter backwashing. It is recommended that weirs not be operated with a head below 0.2
feet.
10. The operators said that the weir's accuracy was verified by running the backwash pumps until the flow at
the effluent matched SCADA's estimation for the pump's flow. However, unless the pumps' flow was
calibrated before conducting this check, the accuracy may have been questionable.
V. Operations and Maintenance .
The plant is operated as required.All operators are properly designated and hold adequate certifications.
The facility appeared to be well operated and managed.
VI. Facility Site Review
The wastewater portion of the facility consists of a series of three settling lagoons. All components
appeared to be operating properly.
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Graham/Mebane WTP, 8/22/2018
VII. Effluent/Receiving Waters
Treated effluent is discharged to Back Creek, class WS-V; NSW waters in the Cape Fear River Basin.
The outfall was readily accessible. Discharged water appeared clear with no visible impact to the receiving
stream.
VIII. Sludge Handling/Disposal
Sludge disposal is handled by Synagro, Inc. Residuals are land applied on City of Graham property under
permit number WQ0003824. Synagro last removed 620,000 gallons of sludge in June and July 2018. Records •
of sludge removal are maintained.
IX. Conclusions and Requested Action
Please provide the information requested under Section IV. Flow Measurement within 30 days of receipt
of this report.
The compliance evaluation inspection is satisfactory. The facility is operated and maintained in an
excellent manner. If you have any questions regarding the inspection or this report, please contact Paul DiMatteo
at [phone] or me at [phone].
Sincerely,
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: BIMS EPA Water Compliance Inspection Report
cc: WSRO
NPDES Unit
Central Files
Page 3 of 3

United States Environmental Protection Agency Form Approved
E PA 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 L 2 IS I 3 I NC0045292 111 12 1 18/08/22 117 18 [ j 19 1.2j 201
21111111 { 11111111111111111111111111111111111r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
671 1 70 1 1 71 I I 72 1 L2_J, 1 731 I r4 751 1 1 1 1 1 1 180
Section 8 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) 02 OOPM 18/08/22 17/07/01
Graham/Mebane WTP
1824 US Hwy 70 Exit Time/Date Permit Expiration Date
Mebane NC 27302 03 OOPM 18/08/22 22/06/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
James E Aiken/ORC//
Name,Address of Responsible Official/Title/Phone and Fax Number •
Contacted
Victor Ray Quick,PO Drawer 357 Graham NC 272530357//336-570-6700/3365135502
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
II Permit • Flow Measurement I Operations&Maintenance • Records/Reports
Self-Monitoring Program • Sludge Handling Disposal • Facility Site Review II Compliance Schedules
• 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
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NC0045292 11 121 18/08/22 117 18 Li
i
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
•
Page# 2

Permit: NC0045292 Owner-Facility: Graham/Mebane WTP
Inspection Date: 08/22/2018 Inspection Type: Compliance Evaluation
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility'? • ❑ ❑ 0
Is the facility compliant with the permit and conditions for the review period'? • 0 0 ❑
Comment: The permit issued effective July 1, 2018 included an 18 month compliance schedule to
install a continuous flow meter.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping'? • 0 0 0
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable ❑ 0 • ❑
Solids, pH, DO, Sludge Judge, and other that are applicable'?
Comment.
PermitYes 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'? • ❑ ❑ 0
#Are there any special conditions for the permit'? 0 IN 0 0
Is access to the plant site restricted to the general public'? • ❑ ❑ 0
Is the inspector granted access to all areas for inspection'? • ❑ ❑ 0
Comment
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit'? • 0 0 0
Is all required information readily available, complete and current'? • ❑ 0 0
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'? 1110 ❑ ❑
Dates, times and location of sampling •
Name of individual performing the sampling MI
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? ❑ ❑ II ❑
Page# 3

Permit: NC0045292 Owner-Facility Graham/Mebane WTP
Inspection Date: 08/22/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
(If the facility Is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ U ❑
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'? • 0 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'? • ❑ ❑ 0
Facility has copy-of previous year's Annual Report on file for review'? ❑ 0 U ❑
Comment:
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 0 ❑
If effluent (diffuser pipes are required) are they operating properly'? ❑ 0 • ❑
Comment' Effluent looked clear with no impact to the receiving stream.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? • ❑ ❑ ❑
Is flow meter calibrated annually'? ❑ 0 • ❑
Is the flow meter operational'? ❑ ❑ ❑ •
(If units are separated) Does the chart recorder match the flow meter'? 0 0 ❑ •
Comment: Please see the inspection letter for comments regarding the new effluent flow metering
method
Lagoons Yes No NA NE
Type of lagoons'?
#Number of lagoons in operation at time of visit'? 3
Are lagoons operated in'? Series
#Is a re-circulation line present'? ❑ MI ❑ ❑
Is lagoon free of excessive floating materials'? • ❑ ❑ ❑
#Are baffles between ponds or effluent baffles adjustable'? ❑ 0 ❑ •
Are dike slopes clear of woody vegetation'? • ❑ ❑ ❑
Are weeds controlled around the edge of the lagoon'? • ❑ ❑ ❑
Are dikes free of seepage'? I 0 ❑ ❑
Are dikes free of erosion'? • ❑ ❑ ❑
Page# 4

Permit: NC0045292 Owner-Facility: Graham/Mebane WTP
Inspection Date: 08/22/2018 Inspection Type: Compliance Evaluation
Lagoons Yes No NA NE
Are dikes free of burrowing animals? • 0 0 0
#Has the sludge blanket in the lagoon(s) been measured periodically in multiple • 0 0 0
locations'?
#If excessive algae is present, has barley straw been used to help control the growth'? 0 0 • 0
Is the lagoon surface free of weeds'? • 0 0 0
Is the lagoon free of short circuiting'? • 0 0 0
Comment Operators said the lagoons are cleaned on a schedule close to
1st lagoon-yearly
2nd lagoon- every other year
3rd lagoon-every 3 to 4 years
Disposal of sludge is handled by Synagro and land applied under Graham's land application
permit Records showed that approximately 620,000 gallons of sludge was removed in June
and July, 2018. •
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ 0 II 0
Is sample collected below all treatment units'? • 0 0 0
Is proper volume collected'? 0 0 ❑ •
Is the tubing clean? 0 0 • 0
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees ❑ 0 0
II
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type 0 0 0 •
representative)?
Comment Permit requires grab samples only.All samples are taken at the 3rd lagoon before final
discharge.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • 0 0 0
Are all other parameters(excluding field parameters) performed by a certified lab'? • 0 0 0
#Is the facility using a contract lab? 0 U 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees 0 0 0 •
Celsius)?
Incubator(Fecal Coliform)set to 44 5 degrees Celsius+/-0 2 degrees'? 0 0 ❑ III
Incubator(BOD)set to 20 0 degrees Celsius+/-1 0 degrees'? ❑ 0 0 •
Comment.
Page# 5

•
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 E 2 ISI 3 I NC0045292 111 12 I 18/09/06 117 18 El I 19 I s I 201
21111111111111IIIIIIII r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -Reserved -
67 1 1 70 I 1 71 1 72 1 N I 731 I 174 " 1 1 1 1 1 1 180
Section B Facility Data LLJJ
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) 11 15AM 18/09/06 17/07/01
Graham/Mebane WTP
1824 US Hwy 70 Exit Time/Date Permit Expiration Date
12 OOPM 18/09/06 22/06/30
Mebane NC 27302
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
James E Aiken/ORC//
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Victor Ray Quick,PO Drawer 357 Graham NC 272530357//336-570-6700/3365135502
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
III Flow Measurement
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/
dailitC314N/1y
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
1., V, i Ll 9014
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NC0045292 111 121 18/09/06 117 18 u
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
This follow up inspection was conducted to evaluate the newly installed flow meter more closely.
Please refer to the accompanying report.
Page# 2

Permit: NC0045292 Owner-Facility Graham/Mebane WTP
Inspection Date: 09/06/2018 Inspection Type: Reconnaissance
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting? U ❑ ❑ ❑
Is flow meter calibrated annually? 00011
Is the flow meter operational? 000 •
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ U
Comment:
•
Page# 3