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NORTH CAROLINA
ROY COOPER Environmental Quolity
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER RECEV�®�®�I��I®WR
Interim Director
August 27, 2018 s
SEP 0 5 201
Mr. Andrew Luter water Re Sect on
YES WL Utilities EXP, LLC Permitting
1900 16th Street, Suite 950
Denver, CO 80202
SUBJECT: Compliance Evaluation Inspection
Woodlake WWTP
NPDES Permit No. NC0023299
Guilford County
Dear Mr. Luter:
On August 21, 2018, Jenny Graznak, of this office, met with Eric Wysong of Apex
Companies, LLC and Randy Bell, operator in responsible charge, to perform a Compliance
Evaluation Inspection on the Woodlake wastewater treatment system. 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 notes the areas that were evaluated for this
inspection. The findings and observations are outlined below:
I. Permit
The NPDES permit became effective January 1, 2017 and expires September 30, 2021. The
facility had a copy of the current permit available during the inspection. The structures seen
in the wastewater treatment system match those listed in the permit.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports (DMRs) for the period January 2017
through December 2018 showed that the facility was in compliance with permit limits with the
exception of the following violations of Biochemical Oxygen Demand (BOD)` and Total
Suspended Solids (TSS):
Parameter Violation Date Violation type
BOD March 2, 2017 Daily Maximum Exceeded
•
BOD April 2017 Monthly Average Exceeded
BOD June 22, 2017 Daily Maximum Exceeded
BOD January 11, 2018 Daily Maximum Exceeded
BOD April 18, 2018 Daily Maximum Exceeded
TSS February 2, 2017 Daily Maximum Exceeded
DQ
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office I 450 W.Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105
336-776-9800
These violations were previously addressed in separate correspondence. Regarding the
permit monitoring requirements, it was noted that all sampling was performed per the
frequencies specified in the permit. Mr. Bell does all sampling for the facility, and the
laboratory analysis is performed by Statesville Analytical, Inc.
III. Laboratory
Mr. Bell is an employee of Bell Enterprises, which holds field parameter certification #5495.
Mr. Bell analyzes pH, dissolved oxygen, temperature, and Total Residual Chlorine at the
facility. The, thermometer was certified by Statesville Analytical on April 10, 2018. Meter
calibrations are documented on the operator log. All other effluent parameters are collected
on Tuesdays with an ISCO 4700 refrigerated composite sampler. The sampler was set at 3
degrees Celsius on the morning of the inspection. The tubing appeared to be clean. Mr. Bell
stated that he changes the tubing every six months or as needed. Mr. Bell delivers the
samples to a courier for Statesville Analytical, Inc.
IV. Records/Reports
A visitation log was on site showing visitation times and plant conditions. Chain of custody
forms and calibration records appeared to be in good order. Ms. Graznak noted no data
transcription discrepancies from bench sheets to DMRs during her documentation review.
V. Flow Measurement
Effluent flow is measured by an ISCO ultrasonic flow meter. The flow meter was calibrated in
June 2018 by Carolina Technical Services, and documentation of the calibration was
available during the inspection. The composite sampler is set up to collect flow proportional
samples.
VI. Operations and Maintenance
This summer, three new blowers were installed, the existing blower piping was replaced, and
the old diffusers were replaced with new 9"fine bubble diffusers. The new diffusers appeared
to be operating properly. The Back Up ORC for the facility Bradley Flynt.
VII. Facility Site Review
The treatment system appeared to be functioning appropriately on the day of the inspection.
However, Ms. Graznak did note a few issues. First, the lift station has an auto-dialer with a
visual and audible alarm. When Mr. Wysong called the auto-dialer during the inspection, it
stated low battery. Please change the battery in the auto-dialer as soon as possible.
In addition, Mr. Bell was unable to crank the generator during the inspection. It was
determined after the inspection that he was incorrectly starting it. Mr. Flynt started the
generator the following morning. Mr. Flynt stated that he runs the generator under load every
6 months. Please exercise the generator monthly, and document the exercise events
and maintenance in a generator log.
Page 2 of 3
The effluent is disinfected with calcium hypochlorite tablets and dechlorinated with sodium
sulfite tablets. Both tablets were available in bulk at the site on the day of the inspection.
VIII. Effluent/Receiving Waters
The effluent from the facility was clear the day of the inspection. Effluent is discharged into
an unnamed tributary to Polecat Creek, classified as Water Supply III waters, in the Cape
Fear River Basin. The outfall pipe can be seen from the stream crossing at Country Club
Drive. The effluent appeared clear on the day of the inspection. Ms. Graznak did,not observe
any floating solids or foam in the discharge. The upstream sample is collected just before the
dam of the lake. The downstream sample is collected on the other side of the Country Club ,
Drive, approximately 100 feet from the outfall.
IX. Sludge Maintenance and Handling
Sludge removal records were available for review during the inspection. Jenkins Waste
Management Company removes sludge from the lift station, chlorine contact chamber, and
sludge digester monthly. The entire contact chamber was pumped out on August 10, 2018.
X. Required Action
In conclusion, the battery in the auto-dialer needs to be replaced. Also, the generator should
be exercised monthly, and documentation of its maintenance and operation should be kept
with the other records and reports for the facility.
If you have any questions regarding the inspection or this report, please contact Ms.
Graznak or me at (336) 776-9800 or by email at iennv.graznakancdenr.gov or
sherri.knight@ncdenr.gov.
Sincerely,
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: EPA Water Compliance Inspection Report
cc: Central Files
WSRO
NPDES Unit
Page 3 of 3
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 L 2 I5 1 3 I N00023299 111 12 I 18/08/21 117 18 1,.1 19 Li i 201
211 11111 1111111111111111111111111 11111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
671 I 70 I
1 71 LI 72 1 ni 1L-1 73I I I74 75J 11111 I 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) 10:00AM 18/08/21 17/01/01
Woodlake MHC WWTP
Exit Time/Date Permit Expiration Date
5418 Country Club Rd
11 30AM 18/08/21 21/09/30
Greensboro NC 27406
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Randall Keith BeIUORC/336-373-7514/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Andrew Luter,1900 16th St Ste 950 Denver CO 80202//303-468-0521/
No
Section C.Areas Evaluated Dunng Inspection(Check only those areas evaluated)
• Permit • Flow Measurement • Operations&Maintenance II Records/Reports
• Self-Monitoring Program • Sludge Handling Disposal IN Facility Site Review • 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
Jennifer F Graznak WSRO WQ//336-771-5000/ 23/21/2-01 S,
Signature
f2-
9at..41.56
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 (Cont.) 1
31 NC0023299 111 121 18/08/21 117 18I I
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
I. Permit
The NPDES permit became effective January 1,2017 and expires September 30, 2021.The facility
had a copy of the current permit available during the inspection.The structures seen in the wastewater
treatment system match those listed in the permit.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports (DMRs)for the period January 2017 through
December 2018 showed that the facility was in compliance with permit limits with the exception of the
following violations of Biochemical Oxygen Demand (BOD) and Total Suspended Solids(TSS).
Parameter Violation Date Violation type
BOD March 2, 2017 Daily Maximum Exceeded
BOD April 2017 Monthly Average Exceeded
BOD June 22, 2017 Daily Maximum Exceeded
BOD January 11, 2018 Daily Maximum Exceeded
BOD April 18, 2018 Daily Maximum Exceeded
TSS February 2, 2017 Daily Maximum Exceeded
These violations were previously addressed in separate correspondence. Regarding the permit
monitoring requirements, it was noted that all sampling was performed per the frequencies specified in
the permit. Mr. Bell does all sampling for the facility, and the laboratory analysis is performed by
Statesville Analytical, Inc.
III. Laboratory
Mr. Bell is an employee of Bell Enterprises,which holds field parameter certification#5495. Mr. Bell
analyzes pH, dissolved oxygen,temperature, and Total Residual Chlorine at the facility.The
thermometer was certified by Statesville Analytical on April 10, 2018. Meter calibrations are
documented on the operator log.All other effluent parameters are collected on Tuesdays with an ISCO
4700 refrigerated composite sampler.The sampler was set at 3 degrees Celsius on the morning of the
inspection.The tubing appeared to be clean. Mr Bell stated that he changes the tubing every six
months or as needed. Mr. Bell delivers the samples to a,courier for Statesville Analytical, Inc.
IV. Records/Reports
A visitation log was on site showing visitation times and plant conditions. Chain of custody forms and
calibration records appeared to be in good order. Ms. Graznak noted no data transcription
discrepancies from bench sheets to DMRs during her documentation review.
V. Flow Measurement
Effluent flow is measured by an ISCO ultrasonic flow meter. The flow meter was calibrated in June
2018 by Carolina Technical Services, and documentation of the calibration was available during the
inspection.The composite sampler is set up to collect flow proportional samples.
VI. Operations and Maintenance
This summer,three new blowers were installed, the existing blower piping was replaced, and the old
diffusers were replaced with new 9"fine bubble diffusers.The new diffusers appeared to be operating
properly. The Back Up ORC for the facility Bradley Flynt.
VII. Facility Site Review
The treatment system appeared to be functioning appropriately on the day of the inspection. However,
Page# 2
Permit: NC0023299Owner-Facility Woodlake MHC WWTP
Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation
Ms. Graznak did note a few issues. First, the lift station has an auto-dialer with a visual and audible
alarm.When Mr.Wysong called the auto-dialer during the inspection, it stated low battery. Please
change the battery in the auto-dialer as soon as possible.
In addition, Mr. Bell was unable to crank the generator during the inspection. It was determined after the
inspection that he was incorrectly starting it. Mr. Flynt started the generator the following morning. Mr.
Flynt stated that he runs the generator under load every 6 months. Please exercise the generator
monthly, and document the exercise events and maintenance in a generator log.
The effluent is disinfected with calcium hypochlorite tablets and dechlorinated with sodium sulfite
tablets. Both tablets were available in bulk at the site on the day of the inspection.
•
VIII. Effluent/Receiving Waters
The effluent from the facility was clear the day of the inspection. Effluent is discharged into an
unnamed tributary to Polecat Creek, classified as Water Supply III waters, in the Cape Fear River
Basin.The outfall pipe can be seen from the stream crossing at Country Club Drive.The effluent
appeared clear on the day of the inspection. Ms. Graznak did not observe any floating solids or foam in
the discharge.The upstream sample is collected just before the dam of the lake. The downstream
sample is collected on the other side of the Country Club Drive, approximately 100 feet from the outfall.
IX. Sludge Maintenance and Handling
Sludge removal records were available for review during the inspection. Jenkins Waste Management
Company removes sludge from the lift station, chlorine contact chamber, and sludge digester monthly.
The entire contact chamber was pumped out on August 10, 2018.
X. Required Action
In conclusion,the battery in the auto-dialer needs to be replaced.Also, the generator should be
exercised monthly, and documentation of its maintenance and operation should be kept with the other
records and reports for the facility.
Page# 3
MHC WWTP
Permit: NC0023299 Owner-Facility: Woodlake
Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • 000
Does the facility analyze process control parameters,for ex: MLSS, MCRT, Settleable • 000
Solids,pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 00 • 0
application?
Is the facility as described in the permit? 11000
#Are there any special conditions for the permit? 00 • O
Is access to the plant site restricted to the general public'? • 000
Is the inspector granted access to all areas for inspection'? U ❑ ❑ ❑
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit'? • 000
Is all required information readily available, complete and current? M ❑ ❑ ❑
Are all records maintained for 3 years(lab reg. required 5 years)? • 000
Are analytical results consistent with data reported on DMRs? • 000
Is the chain-of-custody complete'? U ❑ ❑ ❑
Dates,times and location of sampling U
Name of individual performing the sampling U
Results of analysis and calibration •
Dates of analysis IN
Name of person performing analyses •
Transported COCs •
Are DMRs complete do they include all permit parameters'? 111000
Has the facility submitted its annual compliance report to users and DWQ? 00 • 0
(If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator 00 • O
on each shift'?
Is the ORC visitation log available and current? • 000
Is the ORC certified at grade equal to or higher than the facility classification'? 11000
Is the backup operator certified at one grade less or greater than the facility classification'? • 000
Is a copy of the current NPDES permit available on site'? M ❑ ❑ ❑
Page# 4
Permit: NC0023299 Owner-Facility: Woodlake MHC WWTP
Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 1E ❑
Comment: A comparison of the April 2018 DMR with the operator records and lab data found that all
values were transcribed correctly.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? • 000
Is flow meter calibrated annually? • 000
Is the flow meter operational? • 000
(If units are separated) Does the chart recorder match the flow meter'? 00110
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a Manual 111
b.Mechanical 0
Are the bars adequately screening debris'? • ❑ ❑ ❑
Is the screen free of excessive debris'? • 000
Is disposal of screening in compliance? • 000
Is the unit in good condition'? • 000
Comment: Screenings are placed into the dumpster on site.
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Diffused
Is the basin free of dead spots? • 000
Are surface aerators and mixers operational'? ❑ ❑ E ❑
Are the diffusers operational'? • ❑ ❑ ❑
Is the foamthe proper color for the treatment process'? • 000
Does the foam cover less than 25%of the basin's surface'? 11000
Is the DO level acceptable? 000 •
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ U
Comment. Each train consists of eight aeration basins.
Page# 5
J ,
Permit: NC0023299 Owner-Facility: Woodlake MHC WWTP
Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater's • 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 0 I 0
Are weirs level's • 0 0 0
Is the site free of weir blockage'? • 0 0 0
Is the site free of evidence of short-circuiting? • 0 0 0
Is scum removal adequate'? • 0 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'? II 0 0 0
Is the sludge blanket level acceptable'?(Approximmely Y4 of the sidewall depth) 0 0 0 •
Comment: Each train consists of three clarifiers.There was some floating scum in some of the
clarifiers.
Disinfection-Tablet Yes No NA NE
Are tablet chlorinators operational'? • 0 0 0
Are the tablets the proper size and type? - • 0 0 ❑
Number of tubes in use'? 4
Is the level of chlorine residual acceptable'? 0 0 0 •
Is the contact chamber free of growth, or sludge buildup'? • 0 0 0
Is there chlorine residual prior to de-chlorination'? 0 0 0 •
Comment: The effluent is disinfected with calcium hypochlorite tablets.
De-chlorination Yes No NA NE
Type of system? Tablet
Is the feed ratio proportional to chlorine amount(1 to 1)? , - 0 0 • 0
Is storage appropriate for cylinders? 0 0 • 0
#Is de-chlorination substance stored away from chlorine containers'? 0 0 U 0
Comment:
Are the tablets the proper size and type? • 0 0 0
Are tablet de-chlorinators operational'? • 0 0 0
Number of tubes in use'? 4
Comment: The effluent is dechlorinated with sodium sulfite tablets.
Page# 6
Permit: NC0023299 Owner-Facility: Woodlake MHC WWTP
Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation
Aerobic Digester Yes No NA NE
Is the capacity adequate'? • 0 0 0
Is the mixing adequate'? • 0 0 0
Is the site free of excessive foaming in the tank? • 0 0 0
#Is the odor acceptable'? • 0 0 0
#Is tankage available for properly waste sludge? • 0 0 0
Comment: The blower on the digester is continuous except during wasting.The clear water from
digester flows back to the head of the plant.
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 II 0
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • ❑ 0 0
Is sample collected below all treatment units? II 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: The temperature was 3 degrees Celsius.
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.
Standby Power Yes No NA NE
Is automatically activated standby power available'? 0 II 0 0
Is the generator tested by interrupting primary power source'? 0 • 0 0
Is the generator tested under load'? • 0 0 0
Was generator tested&operational during the inspection'? 0 • 0 0
Page# 7
Permit: NC0023299 Owner-Facility: Woodlake MHC WINTP
Inspection Date: 06/21/2018 Inspection Type: Compliance Evaluation
Standby Power Yes No NA NE
Do the generator(s) have adequate capacity to operate the entire wastewater site'? I 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'? II 0 0 0
Comment: Mr Bell was unable to crank the generator during the inspection. It was determined after the
inspection that he was incorrectly starting it. Mr. Flynt started the generator the following
morning. Mr. Flynt stated that he runs the generator under load every 6 months.
•
Page# 8