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HomeMy WebLinkAboutNC0056561_NOD CEI_20190304 March 04, 2019 Nathan Clark Town of Maggie Valley 3987 Soco Rd Maggie Valley, NC 28751 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2019-PC-0061 Permit No. NC0056561 Maggie Valley WWTP Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Maggie Valley WWTP on February 12, 2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0056561. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Influent Sampling Composite samples are not being collected as required by Section A.(1.) of the permit. _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling The effluent sampler was not set to flow proportional at the time of the inspection. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. Please notify our office once the deficiencies are corrected. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report EC: WQS-ARO Server LF Mike Mehaffey-ORC G:\WR\WQ\Haywood\Wastewater\Municipal\Maggie Valley WWTP 56561\Inspections\EPA Audit Inspection Feb. 12, 2019\20190304_NC0056561_NOD2019PC0061 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0056561 19/02/12 C J31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Maggie Valley WWTP U S Hwy 276 N Maggie Valley NC 28751 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 12:40PM 19/02/12 17/09/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Michael Lee Mehaffey/ORC/828-400-9494/ Other Facility Data 02:20PM 19/02/12 21/03/31 Name, Address of Responsible Official/Title/Phone and Fax Number Michael Lee Mehaffey,3987 Soco Rd Maggie Valley NC 28751//828-926-0866/8289263576 Contacted 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 Pollution Prevention Facility Site Review Pretreatment 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 Linda S Wiggs ARO WQ//828-296-4500 Ext.4653/ Daniel J Boss ARO WQ//828-296-4658/ Timothy H Heim ARO WQ//828-296-4665/ Mikal Willmer Division of Water Quality//828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A 3/5/2019 3/5/2019 3/5/2019 3/6/2019 3/6/2019 NPDES yr/mo/day 19/02/12 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Inspector Mikal Willmer, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Maggie Valley WWTP on February 12, 2019 in conjunction with an EPA Audit of the Asheville Regional Office. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0056561. Inspectors Dan Boss, Linda Wiggs and Tim Heim, with the ARO, and Chris McHugh, with the EPA, were present and assisted in the inspection. ORC Mike Mehaffey, Backup Mike Corbin and Operator Seth Boyd, with the Town of Maggie Valley, assisted in the inspection. Overall the facility is being well maintained and requested data was readily available. The facility utilizes AeroMod technology. Solids are managed using the Town's Class A Distribution permit. Staff reported no major issues experienced at the facility due to heavy rains in 2018. The Town may begin accepting Landfill Leachate again this year. The following deficiencies were noted at the time of the inspection and should be corrected as soon as possible: Influent Sampling: Composite influent samples have been required by permit since, at least, 2006. This deficiency was not noted in previous inspections. Moving forward, composite samples need to be collected to obtain representative influent data to assess removal efficiencies. Influent composite sampling can be either timed or flow proportional. Effluent Sampling: At the time of the inspection, the effluent sampler was set to timed composite. This is only allowed with prior Division approval if flows do not vary by more than 15%. Previous inspections indicated the sampler was set to flow proportional. The sampler needs to be reset to flow proportional as soon as possible. Mr. McHugh discussed the process for resetting the sampler to flow proportional with Maggie Valley staff. Please inform our office once the changes have been implemented. NC0056561 17 (Cont.) Page#2 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP 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 Solids, pH, DO, Sludge Judge, and other that are applicable? Facility staff utilizes settleability results to maintain healthy biota within the aeration basins.Comment: 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? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Permit contains standard Municipal POTW conditions (toxicity & pollutant scans).Comment: Record Keeping 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)? Are analytical results consistent with data reported on DMRs? 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 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? Page#3 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? Files are kept on-site. The last quarter of 2018's data was reviewed during the inspection. ORC, Mr. Mehaffey, reported the 2018 annual pollutant scan was not completed due to a change in the contract laboratory's management. This item will be addressed separately from the inspection. Comment: Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? An ultrasonic flow meter is present at the headworks, but it is used to operate the step mechanical bar screen. Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin’s surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/l) This is not a standard extended aeration facility. Maggie Valley utilizes AeroMod technology in the four aeration basins. Surface DOs are maintained around 6 mg/L. Our readings, at the time of the inspection, were 6.1 mg/L. Air cycles on and turns off for two hours to allow denitrification to occur. Settleability was 250/1000 mL after 30 minutes. Comment: Secondary Clarifier Yes No NA NE 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? Page#4 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP Compliance Evaluation Secondary Clarifier Yes No NA NE 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 solids/pin floc? Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth) Rectangular AeroMod clarifiers (ClarAtors) with air-lift pumps. Weirs are submerged. No excessive solids noted within the clarifiers. Facility staff stated the clarifiers were approximately 14' deep. Both basins had approximately 2.5' of solids. Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Facility mainly utilizes airlift pumps within the facility for solids management.Comment: Aerobic Digester 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? No indication the facility has issues maintaining solids within the facility. There appears to be adequate storage to waste and hold solids before processing for distribution. Comment: Solids Handling Equipment 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? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Facility belt presses sludge before stabilizing with lime. Solids are distributed under the Town's Class A permit (WQ0010615). Approximately 100 dry tons were sent to the landfill in 2018. Comment: Page#5 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP Compliance Evaluation Disinfection-Gas Yes No NA NE 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 lbs 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? Approximately 800 lbs of gas are maintained onsite at one time. Containers are stored and chained next to the disinfection building away from the de-chlorination gas. Feed is flow proportional. Solids are removed from the contact chamber quarterly. Comment: De-chlorination Yes No NA NE Type of system ?Gas Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? Flow proportional feed. Recommend some means of protecting containers from direct sunlight during future upgrades. Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? 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? Page#6 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP Compliance Evaluation Influent Sampling Yes No NA NE Facility has been collecting single grab samples for influent monitoring. This permit deficiency was not mentioned in the previous inspections. Maggie Valley will need to begin collecting composite samples for influent monitoring (used for assessment of 85% removal). Influent composite samples do not need to be flow proportional; timed composite is acceptable. Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Last calibrated by Thurman Horne on 1/16/2019.Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? The last inspection indicated sampling was flow proportional. During the most recent inspection, the composite sampler had been set to time composite (44 samples pulled over 24 hours). The sampler was pulling at least 100 mL per aliquot (significantly larger volume must be set due to distance from intake tubing). Effluent sampling must be set to flow proportional, if not done so already. Constant time/constant volume sampling can only be performed with prior Division approval and only if effluent flow rates vary less than 15 percent. Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? The effluent pipe is visible and accessible along Jonathan's Creek. Rip rap surrounds the bank, no issues with excessive growth. Comment: Upstream / Downstream Sampling Yes No NA NE Page#7 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Permit:NC0056561 Inspection Date:02/12/2019 Owner - Facility: Inspection Type: Maggie Valley WWTP Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Permit requires upstream hardness sampling. ORC reports they collect this sample from the entrance bridge approximately 1000' upstream of the discharge. Comment: Standby Power Yes No NA NE 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? Generator self-tests every Tuesday and tests under load annually. The Town uses StarTek electric. Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # 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? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Facility analyzes field parameters for permit. DO, pH, temperature & chlorine. Daily calibrations and check standards are recorded on bench sheets. Comment: Page#8 DocuSign Envelope ID: 81CB4EBA-6C94-4440-ACE0-6672C5B32E1A Certificate Of Completion Envelope Id: 81CB4EBA6C944440ACE06672C5B32E1A Status: Completed Subject: Please DocuSign: 20190304_NC0056561_NOD2019PC0061.cvr ltr.docx, 20190304_NC0056561_NOD2019PC006... Source Envelope: Document Pages: 10 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 4 Mikal Willmer AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Mar 5, 2019 | 15:01 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Mar 5, 2019 | 15:05 Viewed: Mar 5, 2019 | 15:05 Signed: Mar 5, 2019 | 15:05 Electronic Record and Signature Disclosure: Not Offered via DocuSign Daniel Boss daniel.boss@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Mar 5, 2019 | 15:05 Viewed: Mar 5, 2019 | 15:22 Signed: Mar 5, 2019 | 15:23 Electronic Record and Signature Disclosure: Not Offered via DocuSign Linda Wiggs linda.wiggs@ncdenr.gov DWR DEQ Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Mar 5, 2019 | 15:05 Viewed: Mar 5, 2019 | 15:09 Signed: Mar 5, 2019 | 15:10 Electronic Record and Signature Disclosure: Not Offered via DocuSign Tim Heim tim.heim@ncdenr.gov DWR DEQ Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Mar 5, 2019 | 15:05 Viewed: Mar 6, 2019 | 07:49 Signed: Mar 6, 2019 | 07:50 Electronic Record and Signature Disclosure: Not Offered via DocuSign Signer Events Signature Timestamp G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 174.196.136.177 Signed using mobile Sent: Mar 6, 2019 | 07:50 Viewed: Mar 6, 2019 | 07:55 Signed: Mar 6, 2019 | 07:55 Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Mar 6, 2019 | 07:50 Certified Delivered Security Checked Mar 6, 2019 | 07:55 Signing Complete Security Checked Mar 6, 2019 | 07:55 Completed Security Checked Mar 6, 2019 | 07:55 Payment Events Status Timestamps