NC0051608_Inspection_20181011

NORTH CAROL NA
ROY COOPER fnvrranrh#1t1G1 QUdlfly
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MI HAEL S. REGAL
Secr�rary
LfNDA CULPEPPER
In redm D,'rsctor
11 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
Bandy's High School WWTP
NPDES Permit No. NCO051608
Catawba County
Tracking #: NOD-2018-PC-0301
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 the facility's failures to perform adequate laboratory
controls and appropriate quality assurance procedures (pH and TRC meter calibrations/verifications) which are violations of
the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Laboratory 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 these violations and the issues noted in the Record Keeping and Flow Measurement Sections in the attached report.
In responding, please address your comments to the attention of Mr. Wes Bell.
4;��QEQ5
;Ns�
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
11 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:
F161 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 NCO051608 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 73 L_LJ74 751 I I I I I I I80
u
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)
02:57AM 18/10/02
15/07/01
Bandys High School
2500 N College Ave
Exit Time/Date
Permit Expiration Date
Newton NC 28658
03:30PM 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///
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
EDoby:
Wes Bell e MRO WQ//704-663-1699 Ext.2192/ 10/10/2018
�PiY �e&
A61696D90CC343T
Signature of MaCe i�4ft`4�'WRWbwer Agency/Office/Phone and Fax Numbers Date
H P
Andrew Pitn44"
RO WQ//704-663-1699 Ext.21 10/10/18
1`161 FB69AMUA3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NC0051608 I11 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 and total residual chlorine
meters 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 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.
The ORC was not using the correct gel check standard for the TRC meter verifications (prior to
effluent analyses). In addition, fresh pH standards were not being used pH meter calibrations (prior to
effluent analyses. Please be advised that the subject permit requires the permittee to properly operate
and maintain the facility which includes adequate laboratory controls and appropriate quality assurance
procedures [Permit Condition Reference: Part ll, Section C(2) Proper Operation and Maintenance].
Page#

Permit: NCO051608 Owner - Facility: Bandys High 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: NCO051608
Inspection Date: 10/02/2018
Record Keeping
Owner - Facility: Bandys High 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.
The ORC and staff must ensure the following is clearly reported in the on -site
documentation: lab analyst initials, units of measurement (effluent results and calibration
data), all operation and maintenance activities at each wastewater facility, and the gel check
standard value (verified at lab).
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 (dissolved oxygen, pH, temperature, total residual chlorine,) 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
0
❑
❑
❑
representative)?
Comment: The subiect Dermit reauires 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: NCO051608
Inspection Date: 10/02/2018
Operations & Maintenance
Owner - Facility: Bandys High 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.
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?
0
❑
❑
❑
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 audible and visual alarms NO water level) were tested and operational during the
inspection.
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
0
❑
❑
❑
Are the tablets the proper size and type?
0
❑
❑
❑
Number of tubes in use?
2
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
0
❑
❑
❑
Comment:
De -Chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
0 ❑
❑
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑ ❑
0
❑
Page# 5

Permit: NC0051608 Owner - Facility: Bandys High School
Inspection Date: 10/02/2018 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use? 2
Comment:
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 fortv to fiftv aallons
Per day. These flow values do not appear to be correct following the observation of the
effluent flow rate during the inspection. Facility staff must re-evaluate the daily
discharge
flows to ensure accurate flow values are being measured and 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 effluent appeared clear with no floatable solids or foam.
Page# 6