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HomeMy WebLinkAboutNC0067342_Other Agency Documents_20190212J��'(ED STgp�s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 Z Science and Ecosystem Support Division z Field Services Branch ° 980 College Station Road �tirq< aRotEo��� Athens, Georgia 30605-2720 February 4, 2019 MEMORANDUM SUBJECT: NPDES Diagnostic Evaluation Inspection Report Transmittal Northview Mobile Home Park WWTP Weaverville, North Carolina SESD Project ID: 19-0067 FROM: Chris McHugh, Environmental Engineer Enforcement Section Field Services Branch Science and Ecosystem Support Division Athens, Georgia THRU: John Deatrick, Chief - Field Services Branch Science and Ecosystem Support Division Athens, Georgia TO: Dennis Sayre, Acting Chief Municipal and Industrial Enforcement Section Water Protection Division Atlanta, Georgia Attached is a copy of the NPDES Diagnostic Evaluation Inspection (DE) Report for the inspection conducted at the Northview Mobile Home Park WWTP located at Northview Park Road, Weaverville, NC. The DE was conducted from November 26-28, 2018. The recommendations included in this report reflect the operational conditions and configuration of the WWTP at the time of the EPA evaluation. Suggestions and recommendations should be reviewed and implemented applicable to the current WWTP unit processes. Please forward copies of the report to the appropriate parties. If you have any questions concerning the diagnostic evaluation, please call me at (706) 355-8652 or email me at Mchugh.christopher@epa.gov. Attachment: Cc (via email): Mary Jo Bragan, USEPA, WPD, NPDES Permitting and Enforcement Branch Andrea Zimmer, USEPA, WPD, NPDES Permitting and Enforcement Branch Sara Schiff Janovitz, USEPA, WPD, State of North Carolina Pacesetter Mary Mattox, USEPA, WPD, NPDES Permitting and Enforcement Branch Project ID: 19-0067 NPDES Diagnostic Evaluation Inspection Report Northview Mobile Home Park WWTP Northview Park Road Weaverville, NC, 28787 Project Date: November 26-28, 2018 Report Date: February 4, 2019 Project Leader: Chris McHugh Environmental Engineer, EIT Enforcement Section Field Services Branch Science & Ecosystem Support Division USEPA — Region 4 980 College Station Road Athens, Georgia 30605-2720 The activities depicted in this report are accredited under the US EPA Region 4 Science and Ecosystem Support Division ISO/IEC 17025 accreditation issued by the ANSI-ASQ National Accreditation Board. Refer to certificate and scope of accreditation AT-1644. C0 7Z C� C U3 Q Requestor: Dennis Sayre, Acting Chief Municipal and Industrial Enforcement Section NPDES Permitting and Enforcement Branch Water Protection Division USEPA — Region 4 61 Forsyth Street SW Atlanta, GA, 30303-8960 Approvals: SESD Project Leader: Gam.- rLlh� Chris McHugh, Environmental Engineer Enforcement Section Field Services Branch Science and Ecosystem Support Division Approving Official: 1 John Deatrick, Chief Field Services Branch Science and Ecosystem Support Division Date 2-jq// el Date SESD ID: 19-0067 Final Report Page 2 of 31 Table of Contents 1. INTRODUCTION................................................................................................................. 4 2. BACKGROUND................................................................................................................... 4 3. SUMMARY AND RECOMMENDATIONSO.................................................................... 5 4. FACILITY SITE REVIEW................................................................................................. 7 5. PERMIT.................................................................................................................................8 6. FLOW MEASUREMENT................................................................................................... 8 7. SLUDGE HANDLING......................................................................................................... 9 8. SAMPLING.........................................................................................................................10 8.1 FACILITY SAMPLING...................................................................................................... 10 8.2 USEPA SAMPLING ACTIVITIES...................................................................................... 11 9. REFERENCES....................................................................................................................12 List of Tables TABLE 1 - INSPECTION PERSONNEL...................................................................................... 4 TABLE 2 - FLOW MEASUREMENT DEVICE COMPARISON ................................................ 8 TABLE 3 — TOTAL FLOW RECORDED COMPARISON....................................................... 12 TABLE 4 - LEGEND FOR FIGURE 2........................................................................................ 15 TABLE 5 — FLOW METER TOTALIZER COMPARISON....................................................... 17 List of Figures FIGURE 1 - NORTHVIEW MOBILE HOME PARK WWTP FLOW DIAGRAM ................... 14 FIGURE 2 - NORTHVIEW MOBILE HOME PARK WWTP TREATMENT UNIT DIMENSIONS...................................................................................................................... 15 FIGURE 3 — 24-HOUR FLOW DATA FROM EPA FLOW METER ........................................ 19 SESD ID: 19-0067 Final Report Page 3 of 31 NPDES Diagnostic Evaluation Inspection Northview Mobile Home Park WWTP (Permit No. NC0067342) 1. Introduction During the week of November 26, 2018, representatives of the U.S. Environmental Protection Agency (USEPA) Region 4 Science and Ecosystem Support Division (SESD) and the North Carolina Department of Environmental Quality (NCDEQ) conducted a National Pollutant Discharge Elimination System (NPDES) Diagnostic Evaluation Inspection (DE) on Northview Mobile Home Park Wastewater Treatment Plant (WWTP) in Weaverville, North Carolina. The inspection was requested by the NCDEQ Asheville Regional Office to supplement the EPA Diagnostic Evaluation Inspection conducted in July 2018 (Project ID 18-0570). This additional evaluation of the plant's flow measurement system, NPDES sampling equipment, and sludge handling procedures reflects the operation and configuration of the WWTP at the time of the inspection. It is intended to provide technical recommendations to improve the plant's performance. The following people listed in Table I participated in the inspection. Table 1 - Inspection Personnel Inspector Organization Date on site Chris McHugh USEPA Region 4 SESD 11/26/18 — 11/28/18 Louis Salguero USEPA Region 4 SESD 11/26/18 11/28/18 Cornell Gayle USEPA Region 4 SESD 11/26/18 — 11/28/18 Linda Wiggs NCDEQ Asheville 11/26/18 — 11/27/18 Regional Office Landon Davidson NCDEQ Asheville 11/27/18 Regional Office 2. Background The Northview Mobile Home Park WWTP is a privately -owned wastewater treatment plant that serves the Northview Mobile Home Park, consisting of approximately 170 mobile homes. The facility is designed to operate as an extended aeration plant and is permitted as of April 18, 2018, to discharge 0.032 MGD to receiving waters designated as Flat Creek in the French Broad River Basin. Currently, the facility is under a Statutory Tap Moratorium because it was deemed by the SESD ID: 19-0067 Final Report Page 4 of 31 NCDEQ Asheville Regional Office as unable to adequately treat the volume of wastewater flow it receives daily. In July 2018, EPA Region 4 SESD personnel conducted a Diagnostic Evaluation of the Northview Mobile Home Park at the request of the NCDEQ Asheville Regional Office. In summary, the July inspection revealed an excessive amount of solids retained in the treatment system and difficulties verifying the facility's flow measurement and sampling system was adequate for collection of representative composite samples. 3. Summary and Recommendations During the evaluation, an ISCO Signature Series flow meter and ultrasonic sensor were installed and programmed to measure and record the facility's effluent flow rate. The meter collected flow data for the duration of the inspection, and its calibration to the facility's primary flow device (90' v-notch weir plate) was checked multiple times to ensure that the sensor was measuring accurate flow data. Comparisons between the EPA installed flow meter totalizer and the facility's flow meter totalizer, and instantaneous flow checks comparing the facility's flow sensor and the EPA sensor were recorded throughout the inspection (see Table 2, PB260001, P13260002, P13260003, and P13260004). The facility's composite sampling equipment was evaluated to review the equipment accuracy to properly collect a representative sample. Using a graduated cylinder and timer, EPA personnel calculated the sampler's pumping velocity when collecting a sample aliquot. Additionally, the sample refrigerator was evaluated to review the temperature preservation efficiency of a composite sample during the composite period. A sludge judge was used to measure the sludge blanket depth in the facility's circular clarifier and polishing clarifier to evaluate the solids in the treatment system and to compare with the previous inspection. The major findings were as follows: • The circular clarifier had a sludge blanket depth of 7.5 feet with 10 feet total depth, and the polishing clarifier had 3.5 feet with 10 feet total depth. • During the inspection, SESD observed that the circular clarifier weir plates were submerged when the flow rate increased after the hourly aeration blower cycle (see PB270021). • The facility's flow measurement sensor was not within ± 10 % of the facility's primary flow measurement device (90' v-notch weir plate), and based on the operator's comments, the sensor had never been field calibrated to the weir plate (see section 6 below). SESD ID: 19-0067 Final Report Page 5 of 31 • There was no permanently installed staff gage to measure the water level above the weir plate. • After each hourly aeration blower cycle, the facility's flow rate increased to a rate that almost overtops the effluent weir plate, meaning the weir is not adequate to incorporate the additional flow limit set forth in Section A. (2) of the facility's NPDES permit (see PB270024). • The skimmer arm in the circular clarifier was not skimming properly because it was observed above the height of the surface water in the clarifier (see P13270014). • The scum trough in the circular clarifier was below the water surface, allowing water to freely drain through the valve to the digester (see P13270025). • The effluent sample setup was not properly operating due to the position of the tubing coming out of the effluent sample location and the way that it was routed (34 feet) via PVC conduit to the composite sampler. After entering the sampler building, the tubing had an unnecessary dip that could retain sample aliquot (see PB260012). • Calculations using a graduated cylinder and stopwatch revealed that the effluent sample setup was not adequate to collect a sample at the recommended velocity of 2 feet per second (ft/s) to ensure that solids were not being retained in the tubing or excluded from the sample. • The facility's composite sampling set-up was not adequate to preserve the composite sample to below 6° C as required in 40 CFR 136.3 Table II and SM 5210.B, and there was no temperature measuring device inside the sample refrigerator to monitor the temperature (see PB270016). • There were noticeable amounts of floating solids and debris in the chlorine contact chamber. Recommendations are as follows: • Continue to monitor sludge levels throughout the plant and waste more frequently to prevent accumulation of solids in the clarifiers. • Consider modifying the aeration basin blower schedule to better balance the on/off cycle which will create a more stable environment for the microorganisms. • Install a measurement device such as a staff gage so that the water level above the weir can accurately and more easily be measured. • Lower the height of the skimmer arm in the clarifier so that it can properly skim the surface water to remove floating scum from the clarifier into the scum trough. • Adjust the level of the scum trough relative to the surface water in the circular clarifier so that the trough can properly remove scum. • Modify the effluent sampling tubing setup so that there are no unnecessary bends or troughs in the line that could prevent the sampler from collecting representative samples. • Modify the effluent sampling tubing setup so that the existing pump can collect a sample at the rate of at least 2 ft/s by moving it closer to the effluent sampling location or obtain a pump that is rated to collect a sample from the current distance of 34 feet at a velocity of at least 2 ft/s. SESD ID: 19-0067 Final Report Page 6 of 31 • Repair the existing refrigerator door seal or obtain a new sample refrigerator so that the sample is properly preserved according to 40 CFR 136.3 Table II and SM 5210.B. Proper temperature preservation will help prevent sample deterioration. 4. Facility Site Review The WWTP is configured as an extended aerated system. Modifications to the original package plant include the addition of the new aeration basin, circular clarifier, and contact chamber (See Figure 1,2). Influent wastewater enters the plant and the flow is split between both aeration basins and the equalization basin, followed by the circular clarifier. Afterwards, the circular clarifier discharge goes into an Imhoff clarifier (now referred to as polishing clarifier). Some flow is diverted back to the aeration basins (return activated sludge, RAS) and some is wasted to the digester (waste activated sludge, WAS). The old chlorine contact chamber serves as an additional retention unit before flow enters the new contact chamber, where tablets are used to chlorinate and dechlorinate the effluent before final discharge. Figure 1 in Appendix A shows the flow diagram of the facility as determined by the facility operator and confirmed during the inspection. Table 5 lists the size of each treatment unit measured during the inspection. The distance between the effluent sampling location and the sampler was measured at 34 feet. This is discussed in section 8.1. During the inspection EPA observed that the scum trough in the circular clarifier was completely submerged and full of solids (see P13270013). After discussing the purpose of the scum trough, the operator opened the waste valve of the scum trough and the solids were removed. Note the trough was still submerged under the clarifier surface water (see PB270025). Deficiency: The clarifier scum trough is not properly located to remove the scum from the clarifier. Requirement: 40 CFR, Part 122.41 (e), Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control and related appurtenances which are installed or used by the permittee to achieve compliance with the conditions of this permit. Recommendation: The scum trough should be raised over the clarifier surface water. This allows the skimmer arm to brush the floating scum into the trough and not allow the clarifier effluent water to flow freely into the trough. SESD ID: 19-0067 Final Report Page 7 of 31 5. Permit The Northview Mobile Home Park WWTP permit (NC0067342) became effective on April 1, 2018 and will expire on March 31, 2023. Under the permit, the Eaven Brice Partnership can operate an existing 0.032 MGD extended aeration wastewater treatment facility, and after meeting other stipulations, operate a 0.050 MGD facility. 6. Flow Measurement The facility's effluent flow system is composed of a 90 ° v-notch weir primary device and an ultrasonic flow sensor as a secondary flow measurement device. At the time of the inspection, the flow totalizer chart recorder was recording flow as compared to the previous July inspection in which it was not operational (see PB260003). Shown in Table 2, comparisons between the EPA and facility secondary flow sensors indicated an average flow measurement difference of 43.29%. Based on the calibration checks conducted during the inspection, it was verified that the EPA sensor was within f 10% of the facility's primary weir device. Nonetheless, the facility's secondary flow measurement device was not properly calibrated to the facility's primary weir device. This indicates that facility is underreporting its flow measurement data by an average of 43.29%. Table 2 - Flow Measurement Device Comparison Flow Device Device Type Flow (GPM) Percent Difference Date and Time EPA Ultrasonic sensor Secondary 73.77 37.6% 11/26/18 9:00 a.m. Facility Ultrasonic sensor Secondary 46 EPA Ultrasonic sensor Secondary 56.47 46.9% 11/26/18 9:05 a.m. Facility Ultrasonic sensor Secondary 30 EPA Ultrasonic sensor Secondary 15.52 47.8% 11/26/18 9:25 a.m. Facility Ultrasonic sensor Secondary 8.1 EPA Ultrasonic sensor Secondary 13.04 45.6% 11/26/18 9:26 a.m. Facility Ultrasonic sensor Secondary 7.1 EPA Ultrasonic sensor Secondary 20.94 42.7% 11/27/18 9:22 a.m. Facility Ultrasonic sensor Secondary 12 EPA Ultrasonic sensor Secondary 56.93 43.8% 11/27/18 12:17 pm. Facility Ultrasonic sensor Secondary 32 SESD ID: 19-0067 Final Report Page 8 of 31 EPA Ultrasonic sensor Secondary 70 38.6% 12/27/18 17 13:pm. Facility Ultrasonic sensor Secondary 43 Average Percent Difference 43.29% Deficiency: The facility's flow meter is not properly calibrated to the facility's primary flow device (900 v- notch weir) and consequently, is underreporting its effluent flow. Regulatory Requirement: 40 CFR, Part 122.41 (e), Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control and related appurtenances which are installed or used by the permittee to achieve compliance with the conditions of this permit. Recommendation: The facility should have its secondary flow measurement sensor calibrated on -site to match the primary flow measurement device (900 v-notch weir). The first step is to install a staff level gage on the side wall of the effluent contact chamber behind the weir to perform flow verification. As recommended by the NPDES Compliance Inspection Manual 2017, a primary and secondary flow measurement device should be calibrated to with a 10 % difference of each other. 7. Sludge Handling The Northview Mobile Home Park WWTP uses a septic tank hauler company to dispose of the treated sludge. At the time of the inspection, the circular clarifier had a sludge blanket depth of 7.5 feet. The total depth of the clarifier is 10 feet. Additionally, the polishing clarifier had a sludge blanket of 3.5 feet with a total depth of 10 feet. The sludge blanket depth should be kept to less than one-fourth of the clarifier sidewall water depth (CSU 2008). Based on the sludge depth throughout the plant, the operator should gradually increase the amount of WAS. This will lower the sludge blankets and prevent further solids loss during peak flow events. Managing the return and waste of activated sludge is a critical component to properly operate an activated sludge treatment system. SESD observed that the sludge levels in the clarifiers were lower than the previous inspection. However, the solids level in the aeration basin was noticeably higher. When the blowers were on their off cycle, the solids level was approximately one to two feet below the water surface in the aeration basin. During the previous inspection, this level of solids was not visible in the aeration basin. While it is necessary to recycle solids from the clarifiers to retain healthy microorganisms in the aeration basins, wasting solids is also critical to ensure that the solids are not being SESD ID: 19-0067 Final Report Page 9 of 31 retained for too long in the treatment system. Old solids can lead to poor settling and cause additional problems that will affect the plant's effluent quality. The reduction of solids in the system will decrease the sludge blanket levels and prevent further solids loss during peak flow events. 8. Sampling 8.1 Facility Sampling As stated in the facility's NPDES permit, composite sampling is required twice a week for biochemical oxygen demand (BOD5), total suspended solids (TSS), and NH3. Continuous recording is required for Flow. The facility collects the effluent flow composite samples with a Cole Parmer Masterflex pump, model 7024-72. During the inspection, SESD verified with the pump manufacturer that this pump model was last manufactured in 2008 and has a maximum capacity of 1700 mL/min and 600 rpm. To evaluate the sampler, EPA personnel conducted a more in-depth evaluation of the sampler pump accuracy to collect representative samples. Deficiencies: The pump velocity was calculated using a graduated cylinder to measure the sample volume collected and a timer to measure the collection time. With the measured flow rate and known tube diameter (0.25-inch inner diameter), the pump velocity was calculated to be 0.4 feet per second (ft/s) (see Appendix B for calculation). The EPA observed unnecessary bends in the composite sampler tubing that could retain sample aliquots, affecting the tubing purging process and sample representativeness. (see PB260012). Additionally, the composite sample refrigerator door did not properly close, and no thermometer was observed inside the refrigerator to monitor the sample temperature. Regulatory Requirement: 40 CFR, Part 122.41 (e), Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control and related appurtenances which are installed or used by the permittee to achieve compliance with the conditions of this permit. 40 CFR, Part 136 Table II, Required Containers, Preservation Techniques, and Holding Times and SM 5210.B. Temperature should be below 6°C for sample preservation. Recommendations: The facility should reconfigure the setup so that the tubing can be placed in such way that there is a gradual rise from collection point to the sampler. SESD ID: 19-0067 Final Report Page 10 of 31 Also, samples need be collected at a velocity of at least 2.0 ft/s to avoid solids bias and to not allow solids to settle. The facility should either move the existing sampling pump closer to the effluent location or obtain a pump that can adequate achieve at least 2.0 ft/s to avoid solids bias when collecting a sample. Repair the existing refrigerator door seal or obtain a new sample refrigerator so that the sample is properly preserved according to 40 CFR 136.3 Table II and SM 5210.B. The sample incubator should be well -maintained. Also, the temperature should be monitored using a NIST traceable thermometer and recorded. Proper temperature preservation will help prevent sample deterioration. 8.2 USEPA Sampling Activities An ISCO Signature Series flow meter and ultrasonic sensor were installed and programmed to measure and record the facility's effluent flow rate. The sensor was set-up nearby the facility's flow measurement equipment. The meter collected flow data for the duration of the inspection, and its calibration to the facility's primary flow device (90' v-notch weir plate) was checked multiple times to ensure that the sensor was measuring accurate flow data. Throughout the inspection, the EPA flow meter totalizer and the facility's flow meter totalizer were compared to evaluate if the facility's meter was properly totalizing flow. Table 3 shows the comparisons in totalizer values throughout the inspection. Note the EPA totalizer was initially at 786 gallons, and the facility totalizer was at 3,050 gallons. These initial values were subtracted from the comparison results to account for the initial difference in total flow between the totalizers at the start of the comparison. For the duration of the inspection, the EPA flow totalizer recorded 46,053 gallons, while the facility totalizer recorded 25,510 gallons. This 44.6 % percent difference in recorded flow is consistent with the 43.29 % percent difference observed when comparing instantaneous flow checks (see Table 2). During the inspection, the facility's 24-hour flow was within permit limits. As shown in Figure 3 in Appendix C, the flow measured with the EPA flow meter during the 24-hour period from 11/26/18 13:30 to 11/27/18 13:30 p.m. was 0.026 million gallons (26,000 gallons). Based on the data collected, the facility's flow measurement system is not properly calibrated to the primary flow device (900 v-notch weir plate). Until it is properly calibrated, it is expected that the facility will continue to underreport its total flow by upwards of 44.6%. SESD ID: 19-0067 Final Report Page 11 of 31 Table 3 — Total Flow Recorded Comparison EPA Totalizer Facility Totalizer Percent Difference Date and Time (gallons) (gallons) 21,637 16,510 23.7 % 11/27/18 9:22 AM 24,422 18,520 24.2 % 11/27/18 12:30 PM 24,733 18,840 23.8 % 11/27/18 1:13 PM 46,053 25,510* 44.6 % 11/28/18 9:00 AM * The Facility Totalizer appeared to not be recording flow when EPA personnel arrived on site to compare totalizer values the morning of 11/28/18. SESD conducted the field measurement activities following the Sample Analysis Plan (SAP) prepared for the project. All USEPA sampling methods, measurements, and calibrations were conducted in accordance with USEPA Region 4 SESD procedures listed in the SAP. 9. References • "Operation of Wastewater Treatment Plants Vol 1 and 2", 7th Edition, CSU, Sacramento, 2008. • "Teledyne Isco Open Channel Flow Measurement Handbook." 8a' Edition, Teledyne ISCO, 2017. SESD ID: 19-0067 Final Report Page 12 of 31 Appendix A: Facility Diagrams SESD ID: 19-0067 Final Report Page 13 of 31 her I7oeesler Sp1l -- Thla le a dre�.'I, slow carl000 oii�cllll�. iloee only fepment ftw, ooi a haL plp4. Equalixaiio¢ New Amdom Basis � hasiro{F.Q� 3' r �i �l CAdArraGom Basin r K Pthnk e d ulaecletJiler Palietdeg clydll,e� n ami* Not to Scale ---- WAS = Wx3 to Actuated Sludge oidC oxtact _------ RAS=RehuuActiyated Slue }}+r+ C] doer k de-d char Pipe is oewtev auiiell Figure I - Northview Mobile Home Park WWTP Flow Diagram SESD ID: 19-0067 Final Report Page 14 of 31 10' 12' Front Front 2 ' , Middle 1 Middle 6' =End 16' End 10, 10, C9) 4' Figure 2 - Northview Mobile Home Park WWTP Treatment Unit Dimensions Table 4 - Legend for Figure 2 Figure Label Treatment Unit Volume (ft3) Volume (gallons) 1 Digester 400 3,000 2 Old Aeration Basin 3,600 26,928 3 Polishing Clarifier 1,360 10,175 4 Old Cl Contact Chamber 240 2,992 5 Equalization Basin 2,228 16,667 6 Clarifier 452 30,457 7 New Aeration Basin 7,140 53,411 8 New Cl Contact unused 900 6,732 9 New Cl Contact 900 6,732 10 Sampler Location NA NA SESD ID: 19-0067 Final Report Page 15 of 31 Appendix B: Calculations and Raw Data SESD ID: 19-0067 Final Report Page 16 of 31 Pump Velocity: 0022 * Q .0022 *. 0625 gpm V= A = 2=0.4ft/s Tc 0.2 5 inches. 4 * 12 inches ft V = velocity in feet per second (ft/s) Q = flow in gallons per minute (gpm) A = cross -sectional area of tubing in square feet (ft2) Raw Flow Data: The data below represents the total flow digital reading form both the EPA and facility totalizers recorded throughout the duration of the inspection. This data was used to produce the information in Table 3. Table 5 — Flow Meter Totalizer Comparison Flow Device Device Total Flow Percent Date and Time Type (gallons) Difference EPA Totalizer Secondary 786 Initial comparison 11/26/18 Facility Totalizer Secondary 3,050 after setting up 1:34 PM EPA totalizer EPA Totalizer Secondary 22,423 12.8% 11/27/18 9:22 AM Facility Totalizer Secondary 19,560 EPA Totalizer Secondary 25,209 14.4% 11/27/18 12:30 PM Facility Totalizer Secondary 21,570 EPA Totalizer Secondary 25,519 16.6% 11/27/18 1:13 PM Facility Totalizer Secondary 21,890 EPA Totalizer Secondary 46,839 39% 11/28/18 9:00 AM Facility Totalizer Secondary 28,560* * Facility Totalizer appeared to not be recording flow when EPA personnel arrived on site to compare totalizer values the morning of 11/28/18. SESD ID: 19-0067 Final Report Page 17 of 31 Appendix C: 24-hour Flow Chart SESD ID: 19-0067 Final Report Page 18 of 31 NV MHP WWTP 11126118 - 11/27/18 24-Hour Flow Composite Flow Rate (0.026 mgd);Total (0.026 mgal):0.03 4.12 1111 0.114 0.09 O.OS E 0.06 0.05 0.04 0.0 0_02 a.a1 a 3PM BPM 9PM 27 Tue 3AM 0AM 9AM 12PM Nov 26 Mon 2018 11/26/2018 1:30:00 PM - 11/27/2018 1:30:00 PM Figure 3 — 24-hour Flow Data from EPA Flow Meter SESD ID: 19-0067 Final Report Page 19 of 31 Appendix D: Photographic Log SESD ID: 19-0067 Final Report Page 20 of 31 Photo Number PB260001 Date Taken 11/26/18 9:25 AM Author Chris McHugh Description Facility Digital Instantaneous Flow Measurement (8.4 gpm) SESD ID: 19-0067 Final Report Page 21 of 31 Photo Number PB260002 Date Taken 11/26/18 9:25 AM Author Chris McHugh Description EPA Flow meter instantaneous flow measurement (15.52 gpm) SESD ID: 19-0067 Final Report Page 22 of 31 V110 Photo Number PB260003 Date Taken 11/26/18 9:26 AM Author Chris McHugh Description Facility Digital Instantaneous Flow Measurement (7.1 gpm) SESD ID: 19-0067 Final Report Page 23 of 31 �I :---4 _ Photo Number PB260004 Date Taken 11/26/18 9:26 AM Author Chris McHugh Description EPA Flow meter instantaneous flow measurement (13.04 gpm) SESD ID: 19-0067 Final Report Page 24 of 31 Photo Number PB260012 Date Taken 11/26/18 9:48 AM Author Chris McHugh Description Composite sampler tubing dip and PVC conduit that is used to route tubing underground to effluent sample location SESD ID: 19-0067 Final Report Page 25 of 31 Photo Number PB270013 Date Taken 11/27/18 7:52 AM Author Chris McHugh Description Circular clarifier skimmer and scum trough. The trough was turned off and retaining scum. SESD ID: 19-0067 Final Report Page 26 of 31 Photo Number PB270014 Date Taken 11/27/18 7:53 AM Author Chris McHugh Description Circular clarifier skimmer elevated above water level. The skimmer was not skimming the scum off the top of the water surface as it should. SESD ID: 19-0067 Final Report Page 27 of 31 Photo Number PB270016 Date Taken 11/27/18 8:12 AM Author Chris McHugh Description Facility's Composite Sampling Incubator, and orange composite sampling container. The deteriorating seal on the refrigerator door made it difficult to keep the door completely shut and no thermometer was present inside to monitor sample temperature. SESD ID: 19-0067 Final Report Page 28 of 31 Photo Number PB270021 Date Taken 11/27/18 9:08 AM Author Chris McHugh Description Circular clarifier effluent weir trough with flow surging above weir plate. This happens every hour when the facility's aeration blower system cycles off. SESD ID: 19-0067 Final Report Page 29 of 31 Photo Number PB270024 Date Taken 11/27/18 9:17 AM Author Chris McHugh Description Effluent weir with flow rising almost overtop of the weir plate. This happens every hour when the facility's aeration blower system cycles off. The weir height is approximately 6 inches tall measured from the 90' v-notch to the crest. SESD ID: 19-0067 Final Report Page 30 of 31 s', M-M�M Photo Number PB270025 Date Taken 11/27/18 9:25 AM Author Chris McHugh Description Circular clarifier skimmer and scum trough. The trough was turned on during the inspection to remove the retained solids. Note the trough is completely submerged below the top of the water column. END OF REPORT SESD ID: 19-0067 Final Report Page 31 of 31