NC0086304_Inspection_20181010

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ROY COOPER Envrranrh#1t1G1 QUdlfly
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MICHAEL S. REGAL
Secr�rary
LfNDA CULPEPPER
In redm D,'rsctor
10 October 2018
Mr. Rick Sain
Director of Construction and Maintenance
Catawba County Schools
Post Office Box 1010
Newton, North Carolina 28658
Subject: Notice of Deficiency
Compliance Evaluation Inspection
Mill Creek Middle School WWTP
NPDES Permit No. NCO086304
Catawba County
Tracking #: NOD-2018-PC-0298
Dear Mr Sain:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
October 2, 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 Deficiency (NOD) due to an inoperable visual high water alarm on the
recirculation tank as was noted in the previous inspection performed on May 3, 2017 (report issued on May 16, 2017). The
above -noted finding is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as
detailed in the Sand Filters (Low Rate) Section of the attached report. Please be advised that G.S. 143-215.6A provides for a
civil penalty assessment of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars
($25,000.00) per day when the violation is of a continuing nature, 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. Penalties may also be assessed
for any damage to surface waters of the State that may result from the violation.
It is requested that a written response be submitted to this Office by October 31, 2018, detailing the actions taken to
address this violation and the issues noted in the Record Keeping, Laboratory, and Flow Measurement Sections in the
attached report. In responding, please address your comments to the attention of Mr. Wes Bell.
4;��QEQ5
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North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301I Mooresville, North Carolina 28115
704.663.1699

Mr. Rick Sain
Page Two
10 October 2018
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bellkncdenr.gov.
Sincerely,
DocuSigned by:
Aa+ UW H P41-.14
F 161 FB69A2D84A3...
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report

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 15 I 3 I NCO086304 111 12 I 18/10/02 I17 18 I S i 19 i G i 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70 71 [„ I 72 n 73 � i 74 75I I I I I I I I80
u I I
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 oermit Number)
02:34PM 18/10/02
15/08/01
Mill Creek Middle School
1041 Shiloh Rd
Exit Time/Date
Permit Expiration Date
Claremont NC 286109202
02:56PM 18/10/02
20/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
David P McCorkle/ORC/828-217-0362/
Morgan C Williams//828-464-3562 ext 403/8284654442
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Rick Sain,PO Box 1010 Newton NC 28658//828-464-3562/8284654442
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 Inspector(s) Agency/Office/Phone and Fax Numbers Date
EDocuSigned by:
Wes Bell D� MRO WQ//704-663-1699 Ext.2192/ 10/10/2018
A61696D90CC3437...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Andrew Pitne 4-� H P MRO WQ//704-663-1699 Ext.21 10/10/2018
"- F161 FB69A2D84A3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NC0086304 111 121 18/10/02 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
LABORATORY SECTION cont'd:
The ORC was not performing post -analysis calibration checks on the pH meter following field analyses
at multiple sites. Post -analysis calibration checks must be performed in accordance with the NC
Wastewater/Groundwater laboratory certification approved procedures for the analyses of dissolved
oxygen, pH, and total residual chlorine.
Note: The technical guidance documents developed by the Division's Laboratory Certification Unit
detailing these approved laboratory procedures have been emailed to the Catawba County School's
Health & Environmental Coordinator.
Page#

Permit: NCO086304 Owner - Facility: Mill Creek Middle School
Inspection Date: 10/02/2018 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
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: The last compliance evaluation inspection was performed at the facility on 5/3/17 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
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?
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?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Page# 3

Permit: NCO086304
Inspection Date: 10/02/2018
Record Keeping
Owner - Facility: Mill Creek Middle School
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durina the inspection were oraanized and well maintained. Discharae
Monitoring Reports (eDMRs) were reviewed for the period August 2017 through July 2018.
No effluent limit violations were reported. A revised May 2018 edmr will be resubmitted to
include an effluent pH result originally not reported on 8/22/18.
The ORC and staff must ensure the following is clearly documented in the on -site logs: lab
analyst initials; units of measurement (effluent results and calibration data); and all operation
and maintenance activities at each wastewater facilitv.
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?
0
❑
❑
❑
# 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)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑
Comment: On -site field analyses (temperature and pH) are performed under the Catawba County
School System's field laboratory certification #5409. Water Tech Labs (Certification #50)
has also been contracted to perform all remaining permit -required analyses (BOD, TSS,
ammonia, fecal coliform). See "Summary" Section for additional comments.
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
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
❑
❑
representative)?
Comment: The subiect Dermit requires effluent arab samDles. The ORC must ensure that fecal
coliform samples are collected into a sterilized container if samples are not collected directly
into the fecal coliform sample bottle/bag.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCO086304
Inspection Date: 10/02/2018
Operations & Maintenance
Owner - Facility: Mill Creek Middle School
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The wastewater treatment facility appeared to be adequately
treating the wastewater at the
time of the inspection. The permittee must ensure the vegetation around all treatment units
is properly maintained at all times.
Septic Tank
Yes No NA NE
(If pumps are used) Is an audible and visual alarm operational?
❑ ❑
0
❑
Is septic tank pumped on a schedule?
0 ❑
❑
❑
Are pumps or syphons operating properly?
0 ❑
❑
❑
Are high and low water alarms operating properly?
❑ ❑
0
❑
Comment: The septic tanks and recirculation tank are pumped out every summer by a contracted
company (Leatherman Septic Tank Service).
Sand Filters (Low rate)
Yes No NA NE
(If pumps are used) Is an audible and visible alarm Present and operational?
❑0
❑ ❑
Is the distribution box level and watertight?
❑ ❑
0 ❑
Is sand filter free of ponding?
❑ ❑
❑
Is the sand filter effluent re -circulated at a valid ratio?
0 ❑
❑ ❑
# Is the sand filter surface free of algae or excessive vegetation?
0 ❑
❑ ❑
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
❑ ❑
0 ❑
Comment: The facility was not dosing at the time of the inspection.
The visual alarm (high water level) was not operational at the time of the inspection. The
visual alarm must be repaired/replaced. Please be advised that the subject permit requires
the permittee to properly operate and maintain the wastewater facility at all times [Permit
Condition Reference: Part II, Section C(2) Proper Operation and Maintenancel. An
inoperable visual alarm was noted during the previous Compliance Evaluation Inspection
performed on 5/3/17 (inspection report dated 5/16/17). The ORC and staff must initiate
(and
document) the testing of the visual and audible alarms on multiple occasions throughout
the
calendar year to ensure proper operation.
Disinfection - UV
Yes No NA NE
Are extra UV bulbs available on site?
0
❑
❑
❑
Are UV bulbs clean?
❑
❑
❑
Is UV intensity adequate?
0
❑
❑
❑
Is transmittance at or above designed level?
0
❑
❑
❑
Is there a backup system on site?
❑
❑
0
❑
Is effluent clear and free of solids?
0
❑
❑
❑
Comment:
Page# 5

Permit: NC0086304
Inspection Date: 10/02/2018
Owner - Facility: Mill Creek Middle School
Inspection Type: Compliance Evaluation
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 effluent flow values beina measured/reported tvpically ranae from fiftv to sixtv aallons
Per day. These flow values do not appear to be correct following
the observation of the flow
rate once the effluent pump was activated during the inspection.
Facility staff must
re-evaluate the daily discharge flows to ensure accurate flow values are being reported.
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?
❑
❑
0
❑
Comment: The facility was not discharging at the time of the inspection; however, the effluent appeared
clear with no floatable solids or foam during the brief activation of the effluent pump (to verify
operational status).
Page# 6