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HomeMy WebLinkAboutNC0071528_Inspection_20181106NORTH CAROL NA ROY COOPER fnvrranrh#1t1G1 QUdlfly G&V 01tw MICHAEL S. REGAL Secr�rary LfNDA CULPEPPER In redm D,'rsctor 6 November 2018 CERTIFIED MAIL #:7016 1370 0000 2591 1698 RETURN RECEIPT REQUESTED: Mr. Dale Norman Lake Norman Wood HOA Post Office Box 321 Sherrills Ford, North Carolina 28673 Subject: Notice of Violation Compliance Sampling Inspection Lake Norman Woods WWTP NPDES Permit No. NCO071528 Catawba County Tracking #: NOV-2018-PC-0415 Dear Mr Norman: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on October 25, 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. The results of the effluent samples collected during the inspection will be forwarded to you under separate cover. This report is being issued as a Notice of Violation (NOV) due to the following failures to provide proper operation and maintenance: 1) Holes were observed in the metal support structure along the aeration basin and aerated sludge holding tank; 2) The visual and audible alarm system (high water) for the equalization basin was not operational; 3) A severe leakage was observed in the return activated sludge (RAS) piping system; 4) Clarifier weirs were deteriorated with some being bent with uneven flow distribution; 5) Standby power generator was not operational. EQ.:> "-mr 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. Dale Norman Page Two 6 November 2018 All are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Equalization Basin, Aeration Basin, Secondary Clarifier, Aerobic Digester, and Standby Power Sections 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 November 30, 2018, detailing the actions taken to address these violations. In responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at (704) 235-2192, or via email at wes.bellkncdenr. go . 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 I 2 IF I 3 I NCO071528 111 12 I 18/10/25 I17 18 i � 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 Id I 71 [.. I 72 73 L_LJ74 751 I I I I I I I80 I —I 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) 09:05AM 18/10/25 15/05/01 Lake Norman Woods WWTP Marina Ln Exit Time/Date Permit Expiration Date Sherrills Ford INC 28673 11:00AM 18/10/25 20/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Dennis W Murdock/ORC/828-238-4659/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Dale H Norman,PO Box 321 Sherrills Ford NC 28673//828-478-3179/ 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 Wes Bell DocuSigned by: MRO WQ//704-663-1699 Ext.2192/ 11/6/2018 �Piy �e& A616961D90=437— Signature of Manage �,Y4k�F�WWir Agency/Office/Phone and Fax Numbers Date 4" " PIMWQ//704-663-1699 FA Andrew Pitner4 Ext.21 11/6/18 1`161 FB69AMUA3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NC0071528 I11 121 18/10/25 117 18 ISI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On -site Representatives: The following Envirolink, Inc. personnel were in attendance during the inspection: Mr. Chris Bitterman, Mr. Chip White, and Mr. Dennis Murdock. OPERATIONS & MAINTENANCE SECTION cont'd: Overall, the wastewater treatment facility appeared to be adequately treating wastewater at the time of the inspection; however, operation and maintenance issues were noted with the facility's metal structure, equalization basin alarm system, clarifier weirs, and standby generator. See Equalization Basin, Aeration Basin, Secondary Clarifier, and Standby Generator Sections for additional comments. Please be advised that the subject permit requires the permittee to properly operate and maintain the facilityall facilities and systems of treatment and control at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation & Maintenance] Note: The structural integrity concerns and the operation/maintenance of the equalization basin alarm system, clarifier weirs,and standby generator were noted in the previous inspection report (Notice of Deficiency) dated 4/17/17. In addition, the permittee's response to the inspection report (dated 5/4/17) indicated that corrective actions would be completed by a contracted company (Kemp, Inc.) to address the structural integrity concerns along with repairs to the clarifier weirs, equalization basin alarms, and standby generator. Page# Permit: NCO071528 Owner - Facility: Lake Norman Woods WWTP Inspection Date: 10/25/2018 Inspection Type: Compliance Sampling 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? M ❑ ❑ ❑ 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 4/12/17 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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: NCO071528 Inspection Date: 10/25/2018 Record Keeping Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Sampling 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 September 2017 through August 2018. The following violations were reported during the review period: - Daily maximum effluent BOD limit violations (August 2018, July 2018, December 2018); - Daily maximum effluent fecal coliform limit violations (January 2018, October 2017, September 2017); - Daily maximum effluent TSS limit violation (November 2017); - Monthly average effluent ammonia and BOD limit violations (December 2017) All above -noted violations have been previously addressed by the Division through the issuances of either a NOD, NOV, or civil penalty assessment. Revised July and August 2018 edmrs will be resubmitted to include all ORC visitations. 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 analvses (dissolved oxvaen. oH. temperature. total residual chlorine) are performed under Envirolink, Inc.'s field laboratory certification #5212. Statesville Analytical, Inc. (Certification #440) has also been contracted to provide analytical support for all remaining permit -required parameters (BOD, TSS, ammonia, fecal coliform, total nitrogen, total phosphorus). The ORC and staff must ensure to perform post -analysis calibration checks on the dissolved oxygen, 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 dissolved oxygen, PH, and total residual chlorine. The ORC and staff must ensure to not report effluent total residual chlorine values below the lowest standard verified (during annual verification) on the total residual chlorine meter. 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)? Page# 4 Permit: NCO071528 Inspection Date: 10/25/2018 Effluent Sampling Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Sampling Yes No NA NE Comment: The subject permit requires effluent grab samples. 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? Comment: Process control measurements were being performed and documented. See "Summarv" Section for additional comments. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: The facility is equipped with a basket screen in the equalization basin and a coarse screen at the head of the aeration basin (not effective at screening debris). Screenings are disposed into a permitted landfill. Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Comment: The audible and visual alarm system (high water) was not operational. Aeration Basins Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE Page# 5 Permit: NCO071528 Inspection Date: 10/25/2018 Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Sampling Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: Holes were observed in the metal support structure along the aeration basin (adjacent to blower/motor unit) due to corrosion/rust. Note: No wastewater leakages and/or discharges were observed coming out of the holes. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: A severe leakage was observed in the return activated sludge (RAS) line at the influent trough of the secondary clarifier. Several of the clarifier weirs were also severely rusted and deteriorated. 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? 3 Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Page# 6 Permit: NCO071528 Owner - Facility: Lake Norman Woods WWTP Inspection Date: 10/25/2018 Inspection Type: Compliance Sampling Disinfection -Tablet Yes No NA NE 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 ❑ Comment: Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 3 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: Instantaneous effluent flows are determined by the bucket and stop watch method. The ORC has also performed a flow rate verification/calculation by using the influent pump rates and run times. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ 0 ❑ 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 sliahtiv turbid with no foam. The effluent is discharaed into the receiving stream (Lake Norman) via a submerged outfall. The effluent dissolved oxygen, PH, temperature, and total residual chlorine were measured (during the inspection) at 13.1 mg/L (DO), 7.14 SU (pH), 11.5 degrees Celsius (temperature), and <10 ug/L (total residual chlorine). In addition, DWR staff collected effluent BOD, TSS, ammonia, fecal coliform, total nitrogen and total phosphorus samples during the inspection. The results of these effluent samples will be forwarded under separate cover. Page# 7 Permit: NC0071528 Inspection Date: 10/25/2018 Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Sampling Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: The facilitv is eauiDDed with an aerated sludae holdina tank. A contracted comoanv (Lake Norman Sewer & Septic) removes wastewater solids on an as -needed basis. Usage of the sludge holding tank has continued to be limited due the structural integrity concerns (holes, severe corrosion/rust) in the metal support wall that connects with the influent piping system/flow diversion box.. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: The backup generator was not operational at the time of the inspection. In addition, the current wastewater operations staff were not familiar with the operation/testing of the generator. A copy of all maintenance activities and testing events should be kept at the WWTP site (mailbox inside the fence) for review by wastewater staff and DWR personnel. The permittee should also provide a copy of the operation manual to the wastewater staff. Page# 8