NC0046345_Compliance Evaluation Inspection_20181016

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.BEGAN
Secretary 0Fiii NR/DVVR
LINDA CULPEPPER
Interim Director OCT 24 2018
October 16, 2018 Water i,esources
Permitting Section
Scott Jewell
City of Reidsville
110 Vance Street
Reidsville,NC 27320
SUBJECT: Compliance Evaluation Inspection Report
Reidsville WTP
NPDES Permit No. NC0046345
Rockingham County
Dear Mr. Jewell:
On August 24, 2018, Paul DiMatteo of this office met with Robert Joyce, operator in responsible charge
(ORC)to perform a Compliance Evaluation Inspection on the subject wastewater treatment facility. 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 April 30, 2021. 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 August 2015 through June 2018 showed the
following actioned violations, which were addressed through previous correspondence from this office:
PARAMETER VIOLATIONDATE VIOLATION TYPE VIOLATION
ACTION
Chlorine, Total Residual 06/27/2017 Daily Maximum Exceeded Proceed to NOV •
Copper, Total (as Cu) 07/31/2017 Monthly Average Exceeded Proceed to NOV
Chlorine, Total Residual 08/03/2017 Daily Maximum Exceeded Proceed to NOD
Chlorine, Total Residual 08/17/2017 Daily Maximum Exceeded Proceed to NOD
Chlorine, Total Residual 09/13/2017 Daily Maximum Exceeded Proceed to NOV
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NORTHCAROUA
Deparbrantmr ama� /‘/
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
Effluent grab samples are taken at a weir following effluent pumps. The permit added a requirement for
quarterly hardness composite sampling. Mr. Joyce said they acquired a portable composite sampler for this
purpose, and that he sets it to take 50 milliliters (ml) of sample at fixed intervals on a day that the effluent pumps
are run continuously to obtain flow proportional samples. Note that aliquots taken for compositing must be at
least 100 ml in volume.Additionally, care must be taken to ensure that the sample is preserved as required during
collection.
Sample analysis is performed by the City of Reidsville WWTP Lab,Meritech,and Environmental Testing
Solutions.
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 DMRs with bench sheets revealed a systemic error in the reporting of some
parameters. The eDMR system seemed to default the units for these parameters to micrograms per liter, but the
lab reported values in milligrams per liter. The values were transcribed without completing a conversion. The
inspector demonstrated to Mr. Joyce proper data entry and eDMR revision procedures. Mr. Joyce said he would
identify the incorrect DMRs and revise them. This did not appear to be an intentional or malicious error.
IV. Flow Measurement
The newly renewed permit added a requirement for continuous flow measurement. The facility previously
used instantaneous methods to estimate the flow, for example, a bucket and stopwatch or pump hour meters. The
facility now uses a water sensor over a weir after the effluent pumps, which is monitored and totalized using an
Endress and Hauser FMU90. However, the inspector noted several concerns that may affect the accuracy of this
method of flow measurement:
1. The primary device appears to be a 90 degree v-notch weir. However, the weir's crest did not appear to
be sharp (NPDES inspection guidance suggests that the crest should be no more than 1/8 inch thick; the
actual crest appeared to be nearly 1 inch thick). Additionally, the crest plate did not appear to be in one
plane—there was a ledge normal to the upstream side of the weir immediately below the crest.
2. The upstream side of the weir is completely covered by a concrete slab, so calibrating the flow meter by
taking a manual flow measurement at the primary device and comparing it to the flow meter is difficult or
impossible.
3. Mr. Joyce described the level sensor set in the concrete slab as an infrared sensor. However, most of the
infrared water sensors the inspector was able to find descriptions of merely measured the presence or
absence of water and not the height of water. The flow from a standard weir is calculated using the height
of water above the bottom of the weir crest; thus, if the sensor only measures the presence of water at or
above a certain height, it would not accurately account for any variations in the flow rate.
Part II, Section D.3 of the Permit requires that "Appropriate flow measurement devices and methods
consistent with accepted scientific practices shall be selected to ensure the accuracy and reliability of
measurements of the volume of monitored discharges. The devices shall be installed, calibrated and maintained
to ensure the accuracy of the measurements is consistent with the accepted capability of that type of device.
Devices selected shall be capable of measuring flows with a maximum deviation of less than 10% from the true
discharge rates throughout the range of expected discharge volumes. Flow measurement devices shall be
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Graham/Mebane WTP, 8/22/2018
accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the
measurements is consistent with the accepted capability of that type of device."
In order to verify the accuracy of the selected flow measurement system, please provide a complete
description of the instruments used, discharge tables, calibration procedures, and a response to the comments
noted above indicating why the system is capable of measuring flow to within 10% of the true volume within 30
days of receipt of this report.
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 two settling lagoons.All components appeared
to be operating properly.
VII. Effluent/Receiving Waters
Treated effluent is discharged to an unnamed tributary to Troublesome Creek in the Cape Fear River
Basin. The outfall was readily accessible. Discharged water appeared clear with no visible impact to the receiving
stream.
IX. Conclusions and Requested Action
Within 30 days of receipt of this report,please provide the information requested under Section IV. Flow
Measurement, and an update on the progress of the DMR error revisions identified under Section III.
Records/Reports.
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
143-215.6A, Enforcement Procedures, Civil Penalties.
If you have any questions regarding the inspection or this report, please contact Paul DiMatteo at (336)
776-9691 or me at(336) 776-9800.
Sincerely,
• -�
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Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: EPA Water Compliance Inspection Report
cc: WSRO
NPDES Unit
Central Files
Page 3 of 3

I
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 LI] 2 5i 3 I NC0046345 1 1 1 12 1 18/08/24 117 18 Lir. 19 Li 20 I I
211II1 11 [ 11 111 111 I I 1 I I 11I 1 1 I I I I I 1 1 1 1 111 I I I I I r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 - QA Reserved l
67I I 70 I I 71 I I 72 �, 731
I I74 75I 1 1 1 1 1 1 r°Section B Facility Data L�
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 18/08/24 17/07/01
Reidsville WTP
Exit Time/Date Permit Expiration Date
278 Reid Lake Rd
11.00PM 18/08/24 21/04/30
Reidsville NC 27320
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data '
///
Robert Earl Joyce/ORC/336-373-7530/
Name,Address of Responsible OfficiaUTitle/Phone and Fax Number
Contacted
Scott Jewell,1100 Vance St Reidsville NC 27320//336-349-1070/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
• Permit II Flow Measurement U Operations&Maintenance II Records/Reports
• Self-Monitoring Program II Sludge Handling Disposal • 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
Paul DiMatteo WSRO WQ//336-776-9691/
- 1)0—E D Cik/(01/ ipti qN
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
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NPDES yr/mo/day Inspection Type (Cont) 1
31 NC0046345 Ill 121 15/08/24 117 18 [(;
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Flow measurement.
The most recent permit renewal changed the flow monitoring method from'recording"to"continuous"
to be in line with the current water treatment plant permitting strategy. During the inspection I noted
several things that cause me to question the accuracy of their flow measurement strategy*
1.The primary device appears to be a 90 degree v-notch weir. However, the weirs crest did not appear
to be sharp (sources suggest that the crest be no more than 1/8 inch thick, actual crest appeared to be
nearly 1 inch thick), and the crest plate did not appear to be in one plane (there was a ledge extending
normal to the upstream side of the weir immediately below the crest).
2.The upstream side of the weir is completely covered by a concrete slab. How is it possible to
calibrate the flow meter against a measurement taken at the primary device if the device is not
accessible?
3. Mr. Joyce said that they use an infrared level sensor and that the flow meter is calibrated by running
certain electrical currents through it,with a specific current corresponding to a specific flow. However,
in my brief research of infrared water level sensors, all sensors that I saw simply measured the
presence or absence of water like a switch or float, and did not measure the height of the water,which
would be required to obtain an accurate flow measurement.
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Permit: NC0046345 Owner-Facility: Reidsville WTP
Inspection Date: 06/24/2018 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping'? • 0 ❑ 0
Does the facility analyze process control parameters, for ex. MLSS, MCRT,Settleable • 0 0 0
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 ❑ 0 • 0
application?
Is the facility as described in the permit'? • 0 0 ❑
#Are there any special conditions for the permit'? 0 I 0 ❑
Is access to the plant site restricted to the general public'? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection'? ■ ❑ ❑ ❑
Comment
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ ❑ ❑
Is all required information readily available, complete and current'? • 0 ❑ ❑
Are all records maintained for 3 years(lab reg. required 5 years)' • ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? ❑ • ❑ ❑
Is the chain-of-custody complete'? • 0 ❑ ❑
Dates,times and location of sampling •
Name of individual performing the sampling •
Results of analysis and calibration U
Dates of analysis U
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? ❑ ❑ • ❑
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ • ❑
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? I ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification'? U ❑ ❑ ❑
Is a copy of the current NPDES permit available on site'? • 0 0 ❑
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Permit: NC0046345 Owner-Facility: Reidsville WTP
Inspection Date: 08/24/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review'? 0 0 • ❑
Comment. A review of DMR submissions for some quarterly metal analyses revealed that the eDMR's
default units were set to ug/l, but the lab reported values as mg/I.Values were directly
copied into the DMR without completing the conversion (e.g., if the lab reported 5 mg/I, the 5
was entered but the units were not changed so it was entered as 5 ug/I).This error
persisted as far back as the facility has been using eDMR to report results. Mr. Joyce said
that he thought he spoke with someone at DWR about this shortly after registering for eDMR
but was told to just copy the values as he has done,that the system should complete the
conversion for him Unfortunately, no conversions were automatically applied.The
mismatched data should be revised and DMRs resubmitted for these quarters This did not
appear to be an intentional or malicious error
Effluent Pipe Yes No NA NE
Is right of'way to the outfall properly maintained? • 0 0 ❑
Are the receiving water free of foam other than trace amounts and other debris'? • ❑ El ❑
If effluent (diffuser pipes are required) are they operating properly'? ❑ ❑ IN 0
Comment.
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting'? • 0 ❑ El
Is flow meter calibrated annually'? • 0 El ❑
Is the flow meter operational'? ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? El ❑ U El
Comment: See comment in summary.
De-chlorination Yes No NA NE
Type of system? Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)'? ❑ ❑ • ❑
Is storage appropriate for cylinders'? 0 ❑ I ❑
#Is de-chlorination substance stored away from chlorine containers' • ❑ El ❑
Comment:
Are the tablets the proper size and type'? ❑ ❑ • ❑
Are tablet de-chlorinators operational'? El ❑ • ❑
Number of tubes in use'?
Comment
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Permit: NC0046345 Owner-Facility: Reidsville WTP
Inspection Date: 08/24/2018 Inspection Type: Compliance Evaluation
Lagoons Yes No NA NE
Type of lagoons? Facultative
#Number of lagoons in operation at time of visit? 2
Are lagoons operated in? Parallel
#Is a re-circulation line present? • ❑ ❑ ❑
Is lagoon free of excessive floating materials? • 0 0 0
#Are baffles between ponds or effluent baffles adjustable? 0 0 • ❑
Are dike slopes clear of woody vegetation? • 0 ❑ 0
Are weeds controlled around the edge of the lagoon? • 0 0 0
Are dikes free of seepage? • 0 0 ❑
Are dikes free of erosion? • ❑ 0 0
Are dikes free of burrowing animals? • 0 0 0
#Has the sludge blanket in the lagoon (s)been measured periodically in multiple • ❑ 0 0
locations?
#If excessive algae is present, has barley straw been used to help control the growth? 0 0 I 0
Is the lagoon surface free of weeds? • 0 0 ❑
Is the lagoon free of short circuiting? • 0 0 0
Comment
Effluent Sampling Yes No NA NE
•
Is composite sampling flow proportional? 0 0 ❑ U
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 ❑ •
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type 0 ❑ ❑
representative)?
Comment The new permit requires quarterly composite hardness sampling. Mr. Joyce said he
obtained a small, portable composite sampler to accomplish this, and samples at a time
that the effluent pumps are run continuously so that it is equivalent to flow proportional even
though it is sampled at constant time intervals However, Mr Joyce said that the sampler
was set to take 50 ml of sample per aliquot.The sampler should take at least 100 ml per
aliquot, and the volume should be periodically checked using a graduated cylinder. Note also
that care should be taken to ensure that the sample is preserved properly during collection.
Upstream / Downstream Sampling Yes No NA NE
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i
Permit: NC0046345 Owner-Facility: Reidsville WTP
Inspection Date: 08/24/2018 Inspection Type: Compliance Evaluation
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:
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