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NC0020559_Compliance Evaluation Inspection_20190213
ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Frank Frazier, City Manager City of Henderson PO Box 1434 Henderson, NC 27536-1434 NORTH CAROLINA Environmental Quality February 13, 2019 Subject: Compliance Evaluation Inspection Henderson Water Reclamation Facility NPDES Permit NCO020559 Vance County Dear Mr. Frazier: On Thursday, January 31, 2019, Vanessa Manuel of the Raleigh Regional Office conducted a compliance evaluation inspection of the treatment facilities located at Henderson Water Reclamation Facility (WRF). The purpose of this inspection was to ensure compliance with the subject NPDES permit. During the inspection, the presence and cooperation of Harry Lamont Allen, Operator in Responsible Charge (ORC), were helpful and appreciated. Henderson WRF is located at 1646 West Andrews Avenue in Henderson, North Carolina. The facility is a Grade IV Biological Water Pollution Control System with an as -built flow of 4.14 MGD that treats domestic and industrial wastewater. Through NPDES permit NC0020559, the City of Henderson, hereinafter referred to as the City, is authorized to discharge the treated wastewater through outfall 001 to receiving waters designated as Nutbush Creek, a waterbody classified as C waters within the Roanoke River Basin. This NPDES compliance evaluation inspection consisted of the following: • Review of the NPDES permit; • Review of the owner/facility information; • Review of December 2016 — November 2018 monitoring data; • Review of December 2016 — November 2018 compliance history; • On -site inspection of the wastewater treatment units; and • On -site inspection of the discharge outfall. Findings during the pre -inspection rile review were as follows: 1. The current NPDES permit was issued effective November 1, 2012, and expired March 31, 2017. On October 3, 2016, the Division received the City's permit renewal application for the Henderson WRF. The Division is in the process of renewing this NPDES permit. North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh. North Carolina 27609 �1°+\ 919.791.4200 City of Henderson, NPDES Permit NC002OSS9 February 13, 2019 Page 2 of 4 2. As listed in the subject permit, the treatment components include bar screen and grit chamber, primary clarifiers (abandoned), trickling filters (removed), secondary clarifiers (abandoned), pure oxygen activated sludge nitrification basin (abandoned), final clarifiers, tertiary filters, post aeration, UV disinfection with sodium hypochlorite backup, dissolved air flotation sludge thickening, pure oxygen aerobic digester, anaerobic digesters (abandoned), aerobic digester, sludge holding tank and sludge drying beds (abandoned). During the on - site inspection, the ORC stated the abandoned treatment units are no longer part of the wastewater treatment process. This office requests that treatment units that have been abandoned (pure oxygen basin, clarifiers, anaerobic digesters, etc.) and will not be used by the City be properly demolished for employee and environmental safety. All solids, sludge, water, etc., must be removed frone all abandoned units. 3. Beginning December 21, 2016, EPA's NPDES Electronic Reporting Rule requires permittees to submit their discharge monitoring reports (DMRs) electronically, instead of on paper. The City has been using the Division's eDMR system to electronically report its monitoring data beginning with its August 2016 DMR. To learn more about the eDMR system, please visit the Division's eDMR website at hops' ' `dea nc aox-!about/divisions/water-resources,"edmr. 4. The affiliations contact information for the permitted owner/facility is not up-to-date in the Division's data system. After reviewing the NPDES WW Contacts Report, the ORC indicated Thomas M. Spain is no longer associated with Henderson WRF. Please ensure the information Ilse Division has on file for lire City and Henderson WRF is lip -to -date. Having the correct contact information in the Division's data system ensures correspondence is directed to the appropriate person. 5. For the review period December 2016 — November 2018, the following violations were detected: BOD weekly average limit exceeded in March 2017 and April 2018; Ammonia Nitrogen (NH3N) weekly and monthly average limits exceeded in March and April 2017. The Division has issued enforcement actions to the City for these violations. For the 2-year period ending November 2018, Henderson WRF has been compliant with its Whole Effluent Toxicity limit and monitoring requirements. Findings during the inspection were as follows: 6. The operator's log and supporting analytical documentation were consistent and up to date. 7. The following laboratories perform analyses on the samples collected at the Henderson WRF and reported on the Discharge Monitoring Reports: City of Henderson WRF (certified lab number 242); Meritech Inc. (certified lab number 165); and Environment 1 Inc. (certified lab number 10). The Henderson WRF lab reports analytical results for BOD, TSS, NH3N, Fecal Coliform, pH, Dissolved Oxygen, Temperature, and Conductivity. Meritech reports data for the nutrient parameters, Chronic toxicity, and the metals. Environment 1 reports analytical results for Chlorophyll A. An inspection of the meter calibration logs, standards, incubator temperatures (fecal and BOD) showed the WRF laboratory to be compliant with record - keeping requirements. 8. The inspector compared the August 2017 DMR data against the facility's lab data and the contract lab's analytical results. No discrepancies were noted. City of Henderson, NPDES Permit NCO020559 February 13, 2019 Page 3 of 4 9. The inspector observed the following treatment units: influent pump station, which consists of 2 mechanical bar screens, a grit removal system, a 2-foot influent Parshall flume with ultrasonic flow meter, and 4 submersible non -clog 5.0 MGD pumps; a dual train 3-stage biological nutrient removal (BNR) system consisting of 4 anaerobic basins, 2 anoxic zones, 2 oxidation ditches with four 100-HP aerators; two 95-ft diameter clarifiers; 4 tertiary filters with high water alarms; a contact chamber (no chlorine added); a post -aeration tank; 2 ultra- violet light disinfection banks; a 48-inch effluent rectangular weir with ultrasonic flow meter; a drum sludge thickener; caustic feed tanks; an aerobic digester (I MG); a sludge holding tank (I MG); a truck loading station; and 1 emergency generator. I0. The inspector noted the following observations of the treatment components: a) Preliminary Treatment. The mechanical bar screens and grit removal chamber were in operation and did not appear to have any issues that would affect proper operation. The screenings collected after the influent flow passes through these processes are retained in a dumpster before being hauled to the landfill by Waste Industries. The area around these units was clean and well maintained. b) Secondary Treatment. The BNR system was operational the day of the inspection. The inspector did not observe any dead spots within the system at the time of the inspection. No apparent issues of concern were observed. The final clarifier units were operational. Both clarifiers are fitted with brushes on the arm of the sweeper to clean the weirs. The weirs were clean and showed equal weir overflow rates. Effluent from the clarifiers was clear and free of excess solids. Past inspection reports have indicated the clarifier depths to be 16-feet. However, the ORC informed the inspector each clarifier is 20-feet deep. Please confirm and update this office with the correct depth of the final clarifiers. The ORC measured the sludge depth of clarifier #f 1 at I I feet. The sludge depth in clarifier #f2 was not measured. The sludge level within the clarifiers should be maintained at less than 25% of the depth of the clarifier to help prevent washout of the solids. The ORC stated he was aware of the need to reduce the solids level in the clarifiers and Granville Farms had been contacted. The City should take the necessary actions to significantly reduce the level of solids in each clarifier. c) Tertiary Treatment. The type of operation of the tertiary filters is down flow, and the type of filter media used is sand and anthracite. At the time of the inspection, the filter surface appeared free of clogging. The air scour was operational and the clear well appeared free of excessive solids and filter media. d) Disinfection. The facility disinfects the treated wastewater prior to discharge using ultra- violet light. No issues of concern were observed with the disinfection system. e) Sludge Treatment. Waste activated sludge is removed from the clarifiers and pumped to the drum sludge thickener where polymer is added to thicken the solids prior to deposit into the aerobic digester. The ORC stated the solids are retained in the digesters as long as possible to meet the 503 requirements, and then they are removed and stored in the sludge holding tank for hauling. The sludge hauler, Granville Farms, is contracted to haul the solids away. No issues of concern were observed with the sludge treatment system. City of Henderson, NPDES Permit NCO020559 February 13, 2019 Page 4 of 4 11. The inspector observed the effluent discharge to Nutbush Creek via the outfall pipe to be clear with no observable solids or foam. No detrimental impacts to the receiving stream from the effluent discharge were observed. Within 45-days receipt of this letter, please submit a written response to this office indicating actions the City has taken or will take to comply with or resolve the issues noted in items 2 and 10b above, If you have questions or comments about the inspection, this report or the requirements to take corrective action (if applicable), please contact Vanessa Manuel at 919-791-4255 or via email at Vanessa. Manuel cnrncdenr. gov. Sincerely, 4ck Bolich, L.G., Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Attachments: EPA Water Compliance Inspection Deport Cc: RRO-SWP Files Central Files Un-ted 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 yrlmolday Inspection Type Inspector Fac Type 1 1u 1 2 15 1 3 1 NC0020559 J11 12 19101,'31 17 181'1 191 c I 20I I 21 L! LJ I�I 6 Inspectio-. Work Days Facil ty Self -Monitoring Evaluation Rating 81 CA Reserved 67 70 U 71 I_ __I 72 Lt.] 73 i 1 I74 75 80 Section B: Facility Data I 1 I Name and Location of Facility Inspected (For Industrial Users discharg:ng to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oerm,t Number) 0910AM 19101;31 1211101 Henderson WRF NC Hwy 39 Exit Time/Dale Permit Expiration Date Henderson NC 27536 12 05PM 1910111 17,03;31 Name-'s) of Onsite Representative:suTitles(s). Phone and Fax Number{sj Other Facility Data 1, . Harry Lamont Allen.'ORCr' z,j Z— -'132 --YS-Al7 l ►• �, .2Y2— 431— 4091 (,i14H fJ Name Address of Respons'ble OfriciaVTitle/Phone and Fax Number ita�JlicL�ie.@, C.'1�j J+{Q.�.c�e7C contacted -Themee-M-Cpsia PO Box 1434 Henderson NC 275361434119Aa 4 +eeeeF Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit N Flow Measurement E Operations & Maintenance E Records/Reports Self -Monitoring Program E Sludge Handling Disposal E Facility Site Review 0 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 Vanessa E Manuel RRO WO1W449914Bt)?it-- �r�<�t. Signature of Ma game 10 A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. f Page# NPDES yrlmolday Inspection Type ' 3 NCO020559 11 12 19101 31 17 18 r — r Section D: Summary of FindinglComments (Attach additional sheets of narrative and checklists as necessary) See attached inspection report. Page# Permit: NCO020559 owner -Facility: HendensonwRF inspection Date: 01l311201g 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 ❑ ❑ ❑ application? Is the facility as described in the permit? ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ❑ ❑ ❑ Comment: The NPDES oermit NC0020559 ex ired March 31 2017. The Division of Water Resources received the permit renewal aoolication on October 3.2016 Record Keeoing Yes No NA NE Are records kept and maintained as required by the permit? ❑ ❑ ❑ Is all required information readily available, complete and current? ❑ ❑ ❑ 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 24f7 with a certified operator ❑ ❑ 0 ❑ 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? M ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ n Comment: The current design capacity i.e. As -Built Flow of the treatment olant is 4.14 MGD. The permitted flow after authorized expansion is 6.0 MGD. The requirement for 24-hours seven days per week staffing is not required. Operations & Maintenance Yes No NA NE Page# 3 Permit NCO020559 Owner -Facility: HendersonWRF Inspection Date: 0113112019 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑ Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable E ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ Is the wet well free of excessive grease? ❑ ❑ ❑ N ❑ ❑ 11 Are all pumps present? Are all pumps operable? 0 ❑ 11 N ❑ ❑ El Are float controls operable? is SCADA telemetry available and operational? ❑ ❑ ❑ 0 Is audible and visual alarm available and operational? ❑ ❑ ❑ 0 Comment: Bar Screens Yes No NA NE Type of bar screen ❑ a.Manual b.Mechanical Are the bars adequately screening debris? ❑ ❑ ❑ Is the screen free of excessive debris? 0 El ❑ ❑ Is disposal of screening in compliance? M ❑ ❑ 11 M ❑ ❑ ❑ Is the unit in good condition? Comment: Screenings are collected in a dumnster and Waste Industries hauls the screenings to the landfill. Grit Removal Yes No NA NE Type of grit removal a.Manual b.Mechanical Is the grit free of excessive organic matter? ■ ❑ ❑ Is the grit free of excessive odor? M ❑ ❑ # Is disposal of grit in compliance? M D ❑ Page# 4 Permit NCO020559 owner - Facllity; Henderson WRF Inspection Date: 01/31/2019 Inspection Type= Ctmpliance Evaluation Grit Removal Yes No NA NE Comment: The g6t screenings are are collected in a dum ster and hauled to the landfill by Waste Industries - 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 solidWpin floc? Is the sludge blanket level acceptable? (Approximately 1/4 of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ■ ❑ ❑ Comment; The ORC measured the sludge blanket level in final clarifier #2 to be approximately 11-feet. Theo erator stated the clarifier is 20-feet deep, Sludge blankets should be no more than 25% 5-ft. of the depth of the clarifier wall. Theo erators should take the necessary actions to reduce the sludge in the clarifiers. Oxidation Ditches Yes No NA NE Are the aerators operational? El ❑ ❑ Are the aerators free of excessive solids build up? ❑ ❑ ❑ # is the foam the proper color for the treatment process? ❑El ❑ Does the foam cover less than 25% of the basin's surface? M❑ ❑ ❑ Is the DO level acceptable? M ❑ ❑ ❑ Are settleometer results acceptable (> 30 minutes)? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ Cl Are settelometer results acceptable?(400 to 800 m1A in 30 minutes) [l ❑ ❑ Comment: Biological Nutrient Reduction -process is used in the oxidation ditches. Nutrient Removal Yes No NA NE # Is total nitrogen removal required? ❑ . ❑ ❑ # is total phosphorous removal required? ❑ 0 ❑ El Type Biological Page# 5 Permit, NCO020559 owner - Facility: Henderson WRF Inspection Dale: 01l31l2019 Inspection Type: Compliance Evaluation Nutrient Removal Yes No NA NE # Is chemical feed required to sustain process? ❑ M ❑ 11 Is nutrient removal process operating properly? 0 El El 0 Comment: Filtration (High Rate Te[j!§ryj Yes No NA NE Type of operation: Down flow E ❑ ❑ El Is the filter media present? ❑ Is the filter surface free of clogging? ❑ ❑ Is the filter free of growth? ❑ ❑ ❑ Is the air scour operational? 0 ❑ ❑ ❑ Is the scouring acceptable? Is the clear well free of excessive solids and filter media? W ❑ ❑ ❑ Comment: Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? N ❑ ❑ ❑ 0 El ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ Is UV intensity adequate? Is transmittance at or above designed level? N ❑ ❑ ❑ 0 ❑ ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? Comment: The facility employs dual ultra -violet light disinfection systems to meet the reliability recluirements. In addition the plant has a chlorine contact chamber if chlorine needs to be used for disinfection treatment. Standby Power Yes No NA NE Is automatically activated standby power available? M ❑ ❑ ❑ Is the generator tested by interrupting primary power source? M ❑ ❑ ❑ Is the generator tested under load? M ❑ ❑ ❑ Was generator tested & operational during the inspection? ❑ ❑ ❑ 0 Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? ❑ ❑ ❑ Is the generator fuel level monitored? 0 ❑ 0 ❑ Page# 6 Pennit: NC0020559 owner - Facility: Renderson WRF Inspection Date: 01131/2019 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Comment: Fuel for the back-up generator is maintained on site. The inspector observed the diesel fuel level at 6,000 gallons the day of the inspection. The tank holds 8,000 gallons. Pumps-RAS WAS Yes No NA NE Are pumps in place? ■ ❑ ❑ ❑ Are pumps operational? ■ ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? N ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? E ❑ ❑ # Is the facility using a contract lab? 0❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+;- 0.2 degrees? 0 ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +1- 1.0 degrees? ❑ ❑ ❑ Comment: Aerobic Di ester Yes No NA NE Is the capacity adequate? ■ ❑ ❑ ❑ Is the mixing adequate? ■ ❑ ❑ ❑ Is the site free of excessive foaming in the tank? ❑ ❑ ❑ # Is the odor acceptable? ❑ ❑ ❑ # Is tankage available for properly waste sludge? ❑ ❑ ❑ Comment: Drying Beds Yes No NA NE Is there adequate drying bed space? ❑ ❑ El ■ Is the sludge distribution on drying beds appropriate? ❑ ❑ ❑ Are the drying beds free of vegetation? ❑ ❑ ❑ ■ # Is the site free of dry sludge remaining in beds? ❑ ❑ ❑ Is the site free of stockpiled sludge? ❑ ❑ ❑ ■ Is the filtrate from sludge drying beds returned to the front of the plant? ❑ ❑ ❑ 0 Page# 7 Owner - Facility: permit: NGOO20554 Henderson WRF Inspection Date: 0113112019 Inspection Type: oompl once Evaluation QTVinq Beds Yes No NA NE ❑ ❑ ❑ M # Is the sludge disposed of through county landfill? ❑ ❑ ❑ 0 # Is the sludge land applied? ❑ ❑ ❑ (Vacuum filters) Is polymer mixing adequate? Comment: The drying beds are no longer used in the treatment Process. Solids are hauled and land applied by Granville Farms. Solids Handlinta E[Wipment Yes No NA NE © ❑ ❑ ❑ Is the equipment operational? ❑ ❑ ❑ Is the chemical feed equipment operational? ❑ ❑ ❑ Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ❑ ❑ M ❑ Is the site free of sludge buildup on belts and/or rollers of filter press? ❑ ❑ 0 ❑ Is the site free of excessive moisture in belt filter press sludge cake? ❑ ❑ M ❑ The facility has an approved sludge management plan? 0 ❑ ❑ ❑ Comment: Chemical Feed Yes No NA NE ❑ ❑ Is containment adequate? ❑ ❑ is storage adequate? ❑ Are backup pumps available? ❑ ❑ Is the site free of excessive leaking? Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ❑ is sample collected above side streams? M ❑ ■ ❑ ❑ ❑ Is proper volume collected? M ❑ ❑ ❑ Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ Celsius)? Is sampling performed according to the permit? Comment: Effluent Sampling Yes No NA NE Page# 8 Perk: NCO020559 Owner -Facility: Henderson WRF Inspection pate: 01131/2019 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ ❑ . Is sample collected below all treatment un€ts? 0❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ■ ❑ ❑ ❑ # 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 ❑ ❑ El representative)? Comment: 11 stream ! Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency. sampling type, and ❑ ❑ sampling location)? Comment: Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? ❑ ■ ❑ ❑ Is flow meter calibrated annually? ❑ ❑ ❑ Is the flow meter operational? N❑ ❑ ❑ (if units are separated) Does the chart recorder match the flow meter? ❑ 0 N ❑ Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 El ❑ ❑ Is flow meter calibrated annually? ❑ ❑ ❑ Is the flow meter operational? ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: 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? 130011 Comment: Page# g permit NCO020559 Owner -Facility: Henderson WRF Inspection Date: 01/31/2019 Inspection Type: Compliance Evaluation Page# 10