HomeMy WebLinkAboutNC0044253_Inspection_20181108United 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 NCO044253 111 12 I 18/10/22 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 I, 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)
11:33AM 18/10/22
15/07/01
Camp Dogwood WWTP
NCSR 1849
Exit Time/Date
Permit Expiration Date
Sherrills Ford INC 28673
01:20PM 18/10/22
20/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Gregory Alexander Trombello/ORC/704-989-0165/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Carlton Metts,PO Box 39 Sherrills Frd NC 28673/Interim Director/704-478-2135/
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
cusigned by: 11/7/2018
Wes Bell MRO WQ//704-663-1699 Ext.2192/
e
E�:
96D90=43T
Signature of Mana rROCYR'il"AINer Agency/Office/Phone and Fax Numbers Date
CA44"P 11/8/18
Andrew PitneO WQ//704-663-1699 Ext.21
1`161 FB69AMUA3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
NPDES yr/mo/day Inspection Type (Cont.)
NCO044253 I11 121 18/10/22 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility was issued a NOV for the failures to properly operate and maintain the treatment plant and
retain all permit -required reports during the last inspection performed on 4/3/18. Improvements have
been made to the overall record keeping program; however, no reports and monitoring data had been
maintained for July and August 2018 and no monitoring reports (eDMRS) have been mailed to the
Division since Janaury 2018, as discussed further in the Record Keeping/Summary Section. The
previously cited issues regarding the chlorination and dechlorination units/treatment processes and the
lack of preventive maintenance (blower/motor units) has not been addressed as detailed further in the
Operation & Maintenance, Aeration Basin, Disinfection -Tablet, and Dechlorination Sections. One of the
tablet type treatment units must be relocated downstream of the chlorine contact chamber. In addition,
the second tablet type treatment unit must be re -equipped with tablet sleeves, a cover, and placed
back into service.
RECORD KEEPING SECTION cont'd:
The permittee has retrieved a majority of the permit -required documentation to address the violations
noted in the previous inspection report (dated 4/11/18); however, the July and August 2018
self -monitoring data (eDMRs, lab analyses, chain of custody forms) was not being maintained on -site.
Please be advised that the permittee must maintain three years of permit -required reports and
monitoring data [Reference: NPDES Permit and 15A North Carolina Administrative Code (NCAC) 2B
.0506 (a)(1)(C) & (D)].
The Division has not received the eDMR paper copies (original and copy for each month) since
January 2018. Please be advised that the permittee is required to complete the eDMR submission by
printing, signing, and mailing one original and a copy of the computer -printed eDMR to the Division's
mailing address [Permit Condition Reference: Part I, Section A (3)(1)]. Two eDMRs (original and copy)
for each month from February 2018 to September 2018 must be mailed to the Division. Although the
permittee has previously delegated signature authority to the ORC for eDMR signature and submittal, it
is the permittee's ultimate responsibility to ensure all eDMRs are received by the Division (via
electronically and mail).
Page#
Permit: NCO044253 Owner - Facility: Camp Dogwood WWTP
Inspection Date: 10/22/2018 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
❑
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0
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application?
Is the facility as described in the permit?
0
❑
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# Are there any special conditions for the permit?
0
❑
❑
❑
Is access to the plant site restricted to the general public?
❑
0
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❑
Is the inspector granted access to all areas for inspection?
0
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❑
Comment: The Dermittee has restricted access to the aeration basin. clarifier. blower/motor units
however, the tablet units and chlorine contact chamber are not. This office recommends
restricting public access to the tablet units and chlorine contact chamber to prevent
unauthorized access and/or potential liabilities.
The last compliance evaluation inspection was performed at the facility on 4/3/18 by DWR
staff.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
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0
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Is all required information readily available, complete and current?
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0
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Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
0
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Are analytical results consistent with data reported on DMRs?
0
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Is the chain -of -custody complete?
0
❑
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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 CM
Are DMRs complete: do they include all permit parameters?
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Has the facility submitted its annual compliance report to users and DWQ?
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility classification?
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Is a copy of the current NPDES permit available on site?
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Facility has copy of previous year's Annual Report on file for review?
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Page# 3
Permit: NCO044253
Inspection Date: 10/22/2018
Record Keeping
Owner - Facility: Camp Dogwood WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the period February 2018 through
Auqust 2018. No effluent limit violations were reported and all monitoring frequencies were
correct. See "Summary" Section for additional comments.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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0
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Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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0
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
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Comment: On -site field analvses (DH. temoerature. total residual chlorine) are Derformed under
Metwater, Inc.'s field laboratory certification #5615. Water Tech Labs, Inc. (Certification #50)
has also been contracted to provide analytical support for all remaining permit -required
parameters (BOD, TSS, ammonia, fecal coliform).
The ORC must ensure to perform 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.
The ORC must ensure units of measurement, lab analyst initials, etc. are properly
documented (calibrations, field analyses, etc.) and effluent TRC values are not reported
below the lowest standard verified (during annual verification) on the TRC meter.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
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0
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Is sample collected below all treatment units?
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Is proper volume collected?
M
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Is the tubing clean?
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0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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0
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Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
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representative)?
Comment: The subject permit requires effluent grab samples.
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 ❑ ❑ ❑
Page# 4
Permit: NCO044253 Owner - Facility: Camp Dogwood WWTP
Inspection Date: 10/22/2018 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
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 are Derformed on an as -needed basis. This Office
recommends the ORC increase the frequency of process control measurements. The
facility has a contracted company to remove wastewater solids on an as -needed basis.
The facility was not being properly maintained. No preventive maintenance activities (routine
oil changes, filter cleaning/replacement, etc.) have been established for this treatment
facility. In addition, the chlorination and dechlorination systems were not being properly
operated. See Aeration Basin, Disinfection -Tablet, and Dechlorination Sections for
additional comments. Note: These issues were noted in the previous inspection report
dated 4/11/18. Please be advised that the subject permit requires the permittee to properly
operate and maintain the treatment facility at all times [Permit Condition Reference: Part 11,
Section C(2) Proper Operation & Maintenancel.
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
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Are the bars adequately screening debris?
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0
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
0
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Comment: The facilitv is eauiDDed with a coarse bar screen located in the aeration basin. This bar
screen is not effective in the removal of wastewater debris. Note: No excessive paper
products were observed in the aeration basin and/or clarifier at the time of the inspection.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
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Are surface aerators and mixers operational?
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0
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Are the diffusers operational?
0
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Is the foam the proper color for the treatment process?
0
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Does the foam cover less than 25% of the basin's surface?
0
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Is the DO level acceptable?
0
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
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0
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Page# 5
Permit: NCO044253
Inspection Date: 10/22/2018
Aeration Basins
Owner - Facility: Camp Dogwood WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: One of the blower/motor units did not have any belts. A preventive maintenance
program
has not been implemented for the blower/motor units. The oil in the blowers has not been
changed in years.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
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Is the site free of excessive buildup of solids in center well of circular clarifier?
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0
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Are weirs level?
0
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Is the site free of weir blockage?
0
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Is the site free of evidence of short-circuiting?
0
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Is scum removal adequate?
0
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Is the site free of excessive floating sludge?
0
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Is the drive unit operational?
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0
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Is the return rate acceptable (low turbulence)?
0
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Is the overflow clear of excessive solids/pin floc?
0
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Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
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Comment:
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
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0
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Are the tablets the proper size and type?
0
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Number of tubes in use?
0
Is the level of chlorine residual acceptable?
0
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Is the contact chamber free of growth, or sludge buildup?
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0
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Is there chlorine residual prior to de -chlorination?
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Comment: The DroDer usaae of the tablet chlorinator and chlorine contact chamber has not been
implemented since the issue was addressed in the previous inspection report. Disinfection
has continued to be performed in the clarifier effluent trough and dechlorination is provided
prior to the chlorine contact chamber.
The wastewater solids observed in the chlorine contact chamber need to be removed within
the near future.
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 ❑
Page# 6
Permit: NCO044253 Owner - Facility: Camp Dogwood WWTP
Inspection Date: 10/22/2018 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
# 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? 1
Comment: Dechlorination was not being performed in the correct location as addressed in the previous
inspection report. Dechlorination must be provided after the chlorine contact chamber.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
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0
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Is flow meter calibrated annually?
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0
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Is the flow meter operational?
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0
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(If units are separated) Does the chart recorder match the flow meter?
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0
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Comment: The ORC must ensure flow measurements are Derformed and not estimated. Please note
that flow measurements can be performed on the influent flow as stipulated
in the subject
permit.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
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0
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Are the receiving water free of foam other than trace amounts and other debris?
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If effluent (diffuser pipes are required) are they operating properly?
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0
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Comment: The facility was not discharging at the time of the inspection. The effluent is discharged to
the receiving stream via submerged outfall line.
Page# 7
NORTH CAROL NA
ROY COOPER Envrranrh#1t1G1 QUdlfly
G&V 01tw
MI HAEL S. REGAL
Secr�rary
LfNDA CULPEPPER
In redm D,'rsctor
8 November 2018
CERTIFIED MAIL #:7016 1370 0000 2591 1704
RETURN RECEIPT REQUESTED:
Mr. Carlton Metts, Interim Director
North Carolina Lions, Inc.
Post Office Box 39
Sherrills Ford, North Carolina 28673
Subject: Notice of Violation (NOV) &
Intent to Assess Civil Penalty
Compliance Evaluation Inspection
Camp Dogwood WWTP
NPDES Permit No. NCO044253
Catawba County
Tracking #: NOV-2018-PC-0416
Dear Mr. Metts:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
October 23, 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 previous inspection report dated April 11, 2018, was issued as a Notice of Violation (NOV) due to the failures to
retain permit -required reports and properly operate and maintain the wastewater treatment facility. In particular, the
chlorination and dechlorination treatment units/processes were not being properly operated and the blower/motor units
(aeration basin) were not being properly maintained. DWR staff had determined during this current inspection that no
corrective actions were implemented to address the previously cited operation and maintenance issues and not all permit -
required records were being maintained. A copy of the previous inspection report has been attached to this report for your
review.
EQ.:>
`_=r
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. Carlton Metts
Page Two
8 November 2018
This inspection report is being issued as a NOV & Intent to Assess Civil Penalty due to the permittee's continued failures
to properly operate and maintain the wastewater treatment facility and retain and submit all permit -required
records/monitoring reports which are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-
215.1 as detailed in the Record Keeping/Summary, Operation & Maintenance, Aeration Basin, Disinfection -Tablet, and
Dechlorination 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 violations.
This letter is also to advise you that this Office is considering the initiation of an enforcement action for these operation
and maintenance and record retention/monitoring report submittal violations. It is requested that a written response be
submitted to this Office within ten (10) working days of receipt of this Notice. The response shall include the actions taken to
resolve all violations. In responding, please address your comments to the attention of Mr. Wes Bell. In addition, all eDMRs
(paper copies) from February 2018 to September 2018 must be mailed to the Division by December 7, 2018.
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.bell(&ncdenr.gov.
Sincerely,
EA
DocuSigned by:
oa w H P
F161 FB69A2D84A3...
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosures:
Inspection Reports