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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 ❑ ❑ 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 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? ❑ 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 CM 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: 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 ❑ ❑ ❑ 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 (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? ❑ ❑ 0 ❑ Is sample collected below all treatment units? ❑ ❑ ❑ Is proper volume collected? M ❑ ❑ ❑ 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 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 ❑ 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 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 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ 0 ❑ 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 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ 0 ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) 0 ❑ ❑ ❑ Comment: 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? 0 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? ❑ ❑ ❑ 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? ❑ ❑ 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 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? ❑ ❑ 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 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