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Home My WebLink AboutNC0087645_Compliance Evaluation Inspection_20180925 4"":\* NORTH CAROLINA ROY COOPER Environmental Quality Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director CERTIFIED MAIL# 7013-1710-0002-1922-1937 RECEIVED/DENR/DWR RETURN RECEIPT REQUESTED OCT 0 2 209 8 September 25, 2018 Water Resources Mayor John Wallace Permitting Section Town of Milton PO Box 85 Milton, NC 27305-0085 SUBJECT: Compliance Evaluation Inspection and Notice of Intent to Enforce NOV Tracking Number: NOV-2018-PC-0375 Milton WWTP NPDES Permit No. NC0087645 Caswell County Dear Mr. Wallace: On September 13, 2018, Jenny Graznak, of this office, met with Matt Smith, operator in responsible charge (ORC), to perform a Compliance Evaluation Inspection at the Milton wastewater treatment plant (WVVfP). 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 EPA inspection form details the areas that were evaluated for this inspection. Violations and major areas of concern observed from the inspection are described below. 1. The flow meter at this facility was last calibrated on March 17, 2017, and is, therefore, overdue for calibration. Part II Section D.3 of the permit states that "flow measurement devices shall be accurately calibrated at a minimum of once per year." Please send a copy of the meter's calibration certification immediately upon completion. 2. The generator on site was not functional during the inspection. This was also an issue during last year's compliance evaluation inspection. Part II Section C.7 of the permit states that "the Permittee is responsible for maintaining adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means of alternate power sources, standby generators or retention of inadequately treated effluent." 3. The equalization basin has a visual alarm, but it did not appear to be functioning on the day of the inspection. When the floats were pulled from the basin, the alarm was not triggered. 4. The facility has two blowers for the diffusers in the aeration basin. However, only one of the blowers is functional. The broken blower must be fixed or replaced to provide proper operation and backup for the treatment facility. ,D QV) North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W.Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105 336-776-9800 Y , 5. The effluent discharge pipe was not accessible during inspection, because the right of way to the outfall is not properly maintained. These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Intent to Enforce. Please reply in writing to this letter within 10 calendar days of receiving it. Your written reply should address each of the noted deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. A review of your response will be considered along with any additional information provided. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in.NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 10 calendar days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. Your immediate attention is greatly appreciated, If you have any questions regarding the inspection or this report, please contact Jenny Graznak or me at (336) 776-9800 or by email at iennv.graznak@ncdenr.gov or sherri.knight(a�ncdenr.gov. Sincerely, A, • L-Pt.WilL Sherri V. Knight, P.E. Regional Supervisor Water Quality Regional Operations Division of Water Resources Enclosure: EPA Water Compliance Inspection Report cc: Central Files WSRO NPDES Unit__ r 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 �,,, 2 [ I 3 I NC0087645 ' 111 12 1 18/09/13 117 18[ 1 19 12j I 201 I 211L111111111111111111111111111111111111111111 r6 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved 67I I 70 I I 71 Li 72 LJti l 731 1 174 79 1 1 1 1 1 1 180 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) 09 OOAM 18/09/13 17/10/01 Milton WWTP Exit Time/Date Permit Expiration Date Doll Branch Rd Milton NC 27305 10 30AM 18/09/13 22/05/31 Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Matthew P Smith/ORC/336-414-8274/ Name,Address of Responsible Official/Title/Phone and Fax Number Contacted Michael Behler,PO Box 85 Milton NC 27305//434-251-0097/ No Section C.Areas Evaluated During Inspection(Check only those areas evaluated) • Permit MI Flow Measurement IN Operations&Maintenance IN Records/Reports El Self-Monitoring Program El Sludge Handling Disposal • Facility Site Review II Effluent/Receiving Waters 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 Jennife F Graznak9y, . WSRO WQ//336-771-5000/ c /Z S/2 8 I , 9/�, Imo. Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date I 9/zs/1� ✓•L LLL r� IvC��-�/l� EPA Form 3560-3(Rev 9-94)Previous editions are obsolete. Page# 1 NPDES yr/mo/day Inspection Type (Cont.) 1 31 NC0087645 111 121 18/09/13 117 18 Li Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) PERMIT The NPDES permit became effective October 1, 2017 and expires May 31, 2022.The facility had a copy of the current permit available during the inspection.The structures seen in the WWTP match those listed in the permit. SELF MONITORING PROGRAM A review of the monthly discharge monitoring reports(DMR)for the period April 2017 through September 2018 showed only one violation of Fecal Coliform limits in November 2017. It was also noted that all sampling was performed per the frequencies specified in the permit. The ORC does all sampling for the facility, and the laboratory analysis is performed by Research&Analytical Labs, a NC Certified Lab with certification number 5483. RECORDS/REPORTS The visitation log is on site showing visitation times and plant conditions. Chain of custody forms and calibration records are in good order. Ms. Graznak noted no data transcription discrepancies from bench sheets to DMRs in her documentation review. FLOW MEASUREMENT The flow meter at this facility was last calibrated on March 17, 2017, and is, therefore, overdue for calibration. Effluent flow is measured prior to disinfection. OPERATIONS AND MAINTENANCE ORC Matt Smith is a Grade ll operator and the backup ORC Neal McDuffie is a Grade I operator.The ORC changes the belts on the blowers and changes UV bulbs as needed. Operators typically add soda ash for pH and ammonia control and dog food in the winter when the mixed liquor of the aeration basin decreases. FACILITY SITE REVIEW Multiple issues were noted during the visual inspection of the treatment system -The equalization basin has an alarm, but it did not appear to be functioning on the day of the Inspection. When the floats were pulled from the basin,the alarm was not triggered. -The facility has two blowers for the diffusers in the aeration basin. However, only one of the blowers is functional.The broken blower must be fixed or replaced to provide proper operation and backup for the treatment facility. _ -The operator stated that the generator is set to automatically run for 15 minutes every Monday at 9:00am. However, no one is typically present during this event, so it's unknown if it functions properly. The operator turned power off to the facility, and the generator came on. However, it did not provide power to the plant.Then the generator turned off after 1 or 2 minutes. EFFLUENT/RECEIVING WATERS The effluent from the facility was clear on the day of the inspection. The effluent discharges into Country Line Creek, Class C waters in the Roanoke River Basin.The effluent discharge pipe was not accessible during inspection, because the right of way to the outfall is not properly maintained. SLUDGE HANDLING The ORC stated that the facility does not generate many solids and that the anaerobic sludge holding tank has only been pumped out once since the plant began operating. No sludge records were available for review. Page# 2 Permit: NC0087645 Owner-Facility: Milton 1VMlrP Inspection Date: 09/13/2018 Inspection Type: 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 • ❑ ❑ 0 Solids, pH, DO, Sludge Judge, and other that are applicable'? Comment: Process control data is maintained in a loci sheet by the operator. Permit Yes No NA NE (If the present permit expires in 6 months or less) Has the permittee submitted a new 0 0 • 0 application'? Is the facility as described in the permit'? • 0 0 0 #Are there any special conditions for the permit'? 0 MI 0 0 Is access to the plant site restricted to the general public'? • 0 0 0 Is the inspector granted access to all areas for inspection'? • ❑ 0 0 Comment: The NPDES permit became effective October 1, 2017 and expires May 31, 2022.The facility had a copy of the current permit available during the inspection. The structures seen in the WWTP match those listed in the permit. 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 0 0 Are analytical results consistent with data reported on DMRs? • 0 0 0 Is the chain-of-custody complete'? • 0 0 0 Dates,times and location of sampling • • Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis III Name of person performing analyses U Transported COCl II Are DMRs complete.do they include all permit parameters'? • 0 0 0 Has the facility submitted its annual compliance report to users and DWQ? 0 0 ® 0 (If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 0 • 0 on each shift'? Is the ORC visitation log available and current'? • 0 0 0 Is the ORC certified at grade equal to or higher than the facility classification'? • 0 0 0 Is the backup operator certified at one grade less or greater than the facility classification'? • 0 0 0 Page# 3 Y , Permit: NC0087645 Owner-Facility: Milton VJWrP Inspection Date: 09/13/2018 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? E ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review'? ❑ ❑ • ❑ Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual • b.Mechanical ❑ Are the bars adequately screening debris? • 000 Is the screen free of excessive debris'? • 000 Is disposal of screening in compliance'? • 000 Is the unit in good condition'? M ❑ ❑ ❑ Comment: Equalization Basins Yes No NA NE ' Is the basin aerated? • 000 Is the basin free of bypass lines or structures to the natural environment'? • 000 Is the basin free of excessive grease'? • ❑ ❑ ❑ Are all pumps present'? • ❑ ❑ ❑ Are all pumps operable'? • 000 Are float controls operable? ❑ • ❑ ❑ Are audible and visual alarms operable'? ❑ ■ ❑ ❑ #Is basin size/volume adequate? • 000 Comment: The equalization basin has a visual alarm, but it did not appear to be functioning on the day of the inspection.When the floats were pulled from the basin, the alarm was not triggered. 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'? ❑ ONO Are the diffusers operational'? M ❑ ❑ ❑ Is the foam the proper color for the treatment process'? U ❑ ❑ ❑ Page# 4 • 7 Permit: NC0087645 Owner-Facility: Milton wwTP Inspection Date: 09/13/2018 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Does the foam cover less than 25%of the basin's surface'? • ❑ 0 0 Is the DO level acceptable? 0 0 ❑ • Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ 0 ❑ 0 Comment: The facility has two blowers for the diffusers in the aeration basin. However, only one of the blowers is functional. The broken blower must be fixed or replaced to provide proper operation and backup for the treatment facility. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? • ❑ 0 0 Is the site free of excessive buildup of solids in center well of circular clarifier? 0 0 II ❑ Are weirs level? • 0 0 ❑ Is the site free of weir blockage? • 0 0 0 Is the site free of evidence of short-circuiting? El 0 0 0 Is scum removal adequate'? • 0 ❑ 0 Is the site free of excessive floating sludge? • 0 0 0 Is the drive unit operational? • 0 ❑ 0 Is the return rate acceptable(low turbulence)? • 0 0 0 Is the overflow clear of excessive solids/pin floc? • 0 0 0 Is the sludge blanket level acceptable?(Approximately 1/4 of the sidewall depth) 0 0 0 • Comment: Duckweed covered most of surface of clarifier Disinfection -UV Yes No NA NE Are extra UV bulbs available on site's • 0 0 0 Are UV bulbs clean'? • ❑ ❑ ❑ Is UV intensity adequate? • 0 0 0 Is transmittance at or above designed level'? • 0 ❑ 0 Is there a backup system on site'? • 0 ❑ ❑ Is effluent clear and free of solids'? II 0 ❑ 0 Comment: The effluent is disinfected with a UV system with 6 bulbs that appeared to be functioning on the day of the inspection. Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting'? • ❑ ❑ ❑ Is flow meter calibrated annually'? ❑ II ❑ ❑ Is the flow meter operational'? • 0 ❑ 0 Page# 5 Permit: NC0087645 Owner-Facility: Milton WWfP • Inspection Date: 09/13/2018 Inspection Type: Compliance Evaluation Flow Measurement-Effluent Yes No NA NE (If units are separated)Does the chart recorder match the flow meter? • ❑ 0 0 Comment: The flow meter at this facility was last calibrated on March 17, 2017, and is,therefore, overdue for calibration. Effluent Sampling Yes No NA NE Is composite sampling flow proportional' 0 0 • 0 Is sample collected below all treatment units'? • 0 0 0 Is proper volume collected? 0 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 0 • Celsius)' Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0 representative)? Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained'? 0 • 0 0 Are the receiving water free of foam other than trace amounts and other debris? 0 0 0 • If effluent (diffuser pipes are required) are they operating properly'? 0 0 • 0 Comment: The effluent discharge pipe was not accessible during inspection, because the right of way to the outfall is not properly maintained. Upstream/ Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit(frequency,sampling type,and • 0 0 0 sampling location)' Comment: Anaerobic Digester Yes No NA NE Type of operation Fixed cover Is the capacity adequate? . • 0 0 0 #Is gas stored on site'? ❑ 0 IN 0 Is the digester(s)free of tilting covers'? 0 0 • 0 Is the gas burner operational'? 0 0 II 0 Is the digester heated'? 0 0 II 0 Is the temperature maintained constantly'? 0 0 II 0 Page# 6 e e s Permit: NC0087645 Owner-Facility: Milton WWTP Inspection Date: 09/13/2018 Inspection Type: Compliance Evaluation Anaerobic Digester Yes No NA NE Is tankage available for properly waste sludge'? • 0 0 0 Comment: It is more of a sludge holding tank. Not aerated. Standby Power Yes No NA NE Is automatically activated standby power available? 0 • 0 0 Is the generator tested by interrupting primary power source'? 0 II 0 0 Is the generator tested under load'? 0 U 0 0 Was generator tested&operational during the inspection'? 0 I 0 0 Do the generator(s)have adequate capacity to operate the entire wastewater site? • 0 0 0 Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 • 0 0 Is the generator fuel level monitored'? 0 • 0 0 Comment: The generator on site was not functional during the inspection.This was also an issue during last year's compliance evaluation inspection. r Page# 7