HomeMy WebLinkAboutNC0036196_Inspection_20181220ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. James Wentz, Public Works Director
City of Newton
Post Office Box 550
Newton, North Carolina 28658
Dear Mr. Wentz:
NORTH CAROL NA
crpWro► mertlatQuality
20 December 2018
Subject: Notice of Deficiency
Compliance Evaluation Inspection
City of Newton/Clark Creek WWTP
NPDES Permit No. NCO036196
Catawba County
Tracking #: NOD-2018-PC-0336
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
November 28, 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 following:
- One of the flow measurement systems (Flume #2) is not accessible for calibration;
- The 2017 total residual chlorine meter calibration was not available for inspection;
- The calibration/verification on the total residual chlorine meter had not been performed every twelve
months.
All above -noted findings are violations of the subject NPDES Permit, North Carolina General Statute (G.S.) 143-215.1,
and 15A North Carolina Administrative Code (NCAC) 2H .0805 as detailed in the Record Keeping, Laboratory and Flow
Measurement/Influent 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.
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301 I Mooresville, North Carolina 28115
704.663.1699
Mr. James Wentz
Page Two
20 December 2018
It is requested that a written response be submitted to this Office by January 10, 2019, 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.gov.
Sincerely,
DocuSigned by:
A4,0WW N PZ44.4t4
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 NCO036196 111 12 I 18/11/28 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 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 18/11/28
17/07/01
Clark Creek WWTP
1407 McKay Rd
Exit Time/Date
Permit Expiration Date
Newton NC 28658
01:35PM 18/11/28
20/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
James Eric Jones/ORC/828-695-4370/
Scott Leon Bryan//828-695-4346 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
James Wentz,PO Box 550 Newton NC 28658/Public Works Director/828-465-7400/
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:
Wes Bell MRO WQ//704-663-1699 Ext.2192/ 12/20/2018
Be&
E�:
96D90CC3437...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers DocuSigned by: Date
44" H �'uft12/20/18
EF1611`1369AMUAI.
Andrew Pitner MRO WQ//704-663-1699 Ext.21
.
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
NPDES yr/mo/day Inspection Type (Cont.)
NCO036196 I11 121 18/11/28 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION con'd:
The facility failed to report an effluent ammonia result during the week of 3/25/18 — 3/31/18. A revised
March 2018 eDMR will be submitted to the Division. In addition, the ORC will revise the April and
December 2018 eDMRs to include all ORC visitations.
The ORC and staff must ensure of the following:
- composite sample time (not grab sampling time) is reported on eDMR;
- operator time on -site (24 hrs.) is reported on eDMR for all days of the month including weekends and
holidays;
- effluent conductivity sample time is documented.
The initial annual calibration on the new total residual chlorine (TRC) meter (in 2017) could not be
found. Please be advised that all analytical records must be available for five years as required by 15A
NCAC 2H .0805(a)(7)(G).
FLOW MEASUREMENT - INFLUENT SECTION cont'd:
The stilling wells for both flumes are cleaned on a weekly basis and both flow measurement systems
can be zeroed; however, the second flume is not accessible for calibrations and instantaneous flow
measurement verifications.
Please be advised that the NPDES Permit requires the following: flow measurement devices be
installed, calibrated, and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device; flow measurement devices shall be accurately
calibrated a minimum of once per year; and 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 [Permit Condition Reference: Part ll, Section D(3) Flow Measurements].
Page#
Permit: NCO036196
Inspection Date: 11/28/2018
Owner - Facility: Clark Creek WWTP
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?
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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 last compliance evaluation inspection was performed by DWR staff on 10/6/16.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
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Is all required information readily available, complete and current?
0
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Are all records maintained for 3 years (lab. reg. required 5 years)?
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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: NCO036196
Inspection Date: 11/28/2018
Record Keeping
Owner - Facility: Clark Creek WWTP
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 November 2017 through October
2018. Weekly and monthly average effluent TSS violations were reported in February 2018.
A daily maximum effluent total residual chlorine (TRC) violation was reported in October
2018. The facility failed to monitor for effluent total nitrogen and total phosphorus in January
2018. The Division has separately addressed the January and February 2018 limit and
monitoring violations through the issuances of either a NOV or NOV/assessment of civil
Penalty. The October 2018 limit violation will also be separately addressed by the Division.
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
0
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Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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Comment: Influent and effluent analvses (includina field) are performed by the on -site WWTP laborator
(Certification #143). Meritech, Inc. (Certification #165) has also been contracted to provide
analytical support (metals, low level mercury, TKN, nitrite/nitrate, hardness, toxicity).
The TRC meter had not been calibrated every twelve months as required by the NC
Wastewater/Groundwater Laboratory Certification Approved Procedure for the Analyses of
Total Residual Chlorine.
The facility staff must ensure that all effluent TRC values are not reported below the lowest
standard verified on the TRC meter (annual calibration/verification).
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
0
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Is sample collected above side streams?
0
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Is proper volume collected?
0
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Is the tubing clean?
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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Celsius)?
Is sampling performed according to the permit?
0
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Comment: The subject permit requires influent BOD and TSS composite samples. Monthly aliquot
calibrations/verifications (at a minimum) are performed and documented.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 ❑ ❑ ❑
Page# 4
Permit: NCO036196 Owner - Facility: Clark Creek WWTP
Inspection Date: 11/28/2018 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes No NA NE
Is sample collected below all treatment units?
0
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Is proper volume collected?
0
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Is the tubing clean?
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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Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
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representative)?
Comment: The subiect Dermit reauires composite and arab effluent samples. Monthly aliauot
calibrations/verifications (at a minimum) are performed and documented.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment:
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: The wastewater treatment facility appeared to be properly operated and well maintained.
The facility is staffed with certified operators twenty-four hours per day, seven days per
week with rounds being made every two hours. The ORC and staff incorporate a
comprehensive process control program with all measurements being properly documented
and maintained on -site.
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
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b.Mechanical
Are the bars adequately screening debris?
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:
Flow Measurement - Influent Yes No NA NE
# Is flow meter used for reporting? 0 ❑ ❑ ❑
Page# 5
Permit: NCO036196 Owner - Facility:
Clark Creek WWTP
Inspection Date: 11/28/2018 Inspection Type:
Compliance Evaluation
Flow Measurement - Influent
Yes No NA NE
Is flow meter calibrated annually?
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0
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
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N
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Comment: The facility is equipped with two flow measurement systems (two stilling wells/parshall
flumes) with the second flume mainly used during high flow events. See "Summary"
Section for additional comments.
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
0
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Is the wet well free of excessive grease?
0
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Are all pumps present?
0
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Are all pumps operable?
0
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Are float controls operable?
0
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Is SCADA telemetry available and operational?
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0
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Is audible and visual alarm available and operational?
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0
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Comment:
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
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b.Mechanical
Is the grit free of excessive organic matter?
0
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Is the grit free of excessive odor?
M
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# Is disposal of grit in compliance?
0
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Comment: One of the two grit removal units was in service. Grit and screenings are disposed at the
County Landfill.
Chemical Feed
Yes No NA NE
Is containment adequate?
0
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Is storage adequate?
0
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Are backup pumps available?
0
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Is the site free of excessive leaking?
0
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Comment: Aqueous lime is added to the influent prior to the primary clarifiers.
Page# 6
Permit: NCO036196 Owner - Facility:
Inspection Date: 11/28/2018 Inspection Type:
Clark Creek WWTP
Compliance Evaluation
Primary 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?
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?
0
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Is the sludge blanket level acceptable?
0
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Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
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Comment: Both primaries were operational and in service.
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
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Are surface aerators and mixers operational?
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Are the diffusers operational?
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0
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Is the foam the proper color for the treatment process?
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Does the foam cover less than 25% of the basin's surface?
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Is the DO level acceptable?
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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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Comment: All four aeration basins are operational and equipped with mechanical aeration. One of the
aeration basins was in service due to low influent flows.
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?
Yes No NA NE
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Page# 7
Permit: NCO036196
Inspection Date: 11/28/2018
Secondary Clarifier
Owner - Facility: Clark Creek WWTP
Inspection Type: Compliance Evaluation
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
Comment: All three secondaries were operational; however, only two were in service.
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Filtration (High Rate Tertiary)
Type of operation:
Is the filter media present?
Is the filter surface free of clogging?
Is the filter free of growth?
Is the air scour operational?
Is the scouring acceptable?
Is the clear well free of excessive solids and filter media?
Comment: Both tertiary filters were operational and in service.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment:
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
Down flow
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Page# 8
Permit: NCO036196
Inspection Date: 11/28/2018
Disinfection -Gas
De -chlorination
Type of system ?
Owner - Facility: Clark Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Yes No NA NE
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
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Is storage appropriate for cylinders?
0
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# Is de -chlorination substance stored away from chlorine containers?
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0
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Are the tablets the proper size and type?
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0
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Comment: The chlorination and dechlorination cylinders are stored outside underneath a covered
shelter.
Are tablet de -chlorinators operational?
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0❑
Number of tubes in use?
Comment:
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
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Are the receiving water free of foam other than trace amounts and other debris?
0
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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 effluent appeared clear with no floatable solids or foam.
The receiving stream did not
appear to be negatively impacted.
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
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0
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Is the chemical feed equipment operational?
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0
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Is storage adequate?
0
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Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
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0
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Is the site free of sludge buildup on belts and/or rollers of filter press?
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0
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Is the site free of excessive moisture in belt filter press sludge cake?
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0
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The facility has an approved sludge management plan?
0
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Comment: The centrifuaes have been taken out service for several vears
All four gravity thickeners were operational and in service. City of Conover removes and
transports the thickened wastewater sludge from one of the thickeners to the Regional
Compost Facility for further treatment/processing. City of Newton lime stabilizes the
wastewater sludge in the remaining three thickeners for land application by a contracted
company (Synagro) under the authority of Permit No. WQ0003902.
Page# 9
Permit: NC0036196
Inspection Date: 11/28/2018
Owner - Facility: Clark Creek WWTP
Inspection Type: Compliance Evaluation
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
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Comment: City staff maintain the generator and a contracted company services the generator on a
periodic basis.
Page# 10