NC0058084_Inspection_20190327

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. David Risley
Gough Econ
Post Office Box 668583
Charlotte, North Carolina 28266
Dear Mr. Risley:
NORTH CAROLINA
Environmental Quality
27 March 2019
Subject: Notice of Deficiency
Compliance Evaluation Inspection
Gough Econ WWTP
NPDES Permit No. NCO058084
Mecklenburg County
Tracking #: NOD-2019-PC-0076
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
March 21, 2019, 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 the following:
1) Failure to properly maintain the sand filter (solids removal);
2) Failure to repair the metal support structure for the tablet chlorinator;
3) Failure to properly document effluent results and meter calibrations/verifications for all sampling events;
4) Failure to properly report effluent data on the Discharge Monitoring Reports (eDMRs);
These are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215 as detailed in the Sand
Filter (Low Rate)/Summary, Disinfection -Tablet and Record Keeping/Summary Sections of the attached report. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day may be
assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit
issued pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State that may result
from the violations.
It is requested that a written response be submitted to this Office by April 17, 2019, detailing the actions taken to address all
above -noted violations. hi responding, please address your comments to the attention of Mr. Wes Bell.
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

Mr. David Risley
Page Two
27 March 2019
The report should be self-explanatory; however, should you have any questions concerning this report, please do not
hesitate to contact Mr. Bell at [phone] or at wes.bellgncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
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 15 I 3 I NCO058084 111 12 I 19/03/12 I17 18 I S I 19 I G I 201 I
211111 1 1 I I I I II I I I I I I I I I I I I 1 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 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
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)
09:32AM 19/03/12
15/07/01
Gough Econ WWTP
9400 N Lakebrook Rd Sr
Exit Time/Date
Permit Expiration Date
Charlotte NC 28214
12:30PM 19/03/12
20/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Steven L Lam bert/ORC/704-546-2602/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
David P Risley,PO Box 668583 Charlotte NC 28266/President/704-399-2306/
Yes
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
2 re
Wes Bell cuSignedd by: MRO WQ//704-663-1699 Ext.2192/ 3/26/2019 19E�:
96D90=43T
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger Division of Water Quality//704-2;
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
eyl � 3/27/2019
AlaccsalAFvazs... Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO058084 I11 12, 19/03/12 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
Only one effluent total residual chlorine (TRC) result was reported for the weeks of 4/22/18, 10/28/18
and 12/23/18. The inspection verified that the above -noted monitoring violations were transcription
errors and therefore, revised eDMRs will be submitted and mailed in to the Division. The Permittee
and ORC must ensure that all eDMRs are accurate and complete prior to submittal.
The records reviewed during the inspection were organized and readily accessible; however, there
were several instances of either the pH and TRC effluent results or the meter calibrations/verifications
not being properly documented as required by the subject Permit [Part II, Section D(6) Records
Retention & D(7) Recording Results]. The Permittee and ORC must ensure that all data is properly
documented and maintained.
SAND FILTERS (LOW RATE) SECTION cont'd:
Ponding was observed during the recirculation process and the ORC indicated that the entire sand bed
is submerged during a discharge event from the dose tank. Extensive ponding for extended periods of
time can negatively impact the aerobic biological treatment processes. The Permittee and ORC must
ensure that the sand bed is consistently raked of solids, spent sand is replaced when needed, and the
sand bed is not submerged for extended periods of time. In addition, the Permittee and ORC must
also ensure that no short-circuiting of the initially dosed wastewater (bypasses the recirculation
process) occurs during a discharge event.
Page#

Permit: NCO058084
Inspection Date: 03/12/2019
Owner - Facility: Gough Econ 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
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The last compliance evaluation inspection was performed by DWR staff on 9/12/16.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
❑
0
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
❑
Dates of analysis
Name of person performing analyses
Transported CM
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Comment: Discharae Monitorina Resorts (eDMRs) were reviewed for the period January 2018 throuah
December 2018. Effluent ammonia monthly average violations were reported in January,
May, September, and November 2018. An effluent fecal coliform daily maximum violation
was also reported in January 2018. The Division has previously addressed these limit
violations through the issuances of either a Notice of Deficiency (NOD) or Notice of Violation
(NOW See "Summary" Section for additional comments.
Page# 3

Permit: NCO058084 Owner - Facility: Gough Econ WWTP
Inspection Date: 03/12/2019 Inspection Type: Compliance Evaluation
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑
Comment: On -site field analyses (dissolved oxygen, pH, temperature, TRC) are performed under the
Gough Econ's field laboratory certification #5083. Statesville Analytical Holdings, LLC
(Certification #440) has also been contracted to provide analytical support for all effluent
parameters except field.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
❑
❑
representative)?
Comment: The subiect Dermit reauires effluent arab samples. The ORC and staff must ensure that
effluent samples are collected during a representative discharge event.
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
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?
Comment:
Septic Tank
(If pumps are used) Is an audible and visual alarm operational?
Yes No NA NE
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❑
❑
❑
❑
❑
Yes No NA NE
❑ ❑ ■ ❑
Page# 4

Permit: NCO058084
Owner - Facility: Gough Econ WWTP
Inspection Date: 03/12/2019
Inspection Type: Compliance Evaluation
Septic Tank
Yes No NA NE
Is septic tank pumped on a schedule?
0
❑
❑
❑
Are pumps or syphons operating properly?
0
❑
❑
❑
Are high and low water alarms operating properly?
❑
❑
0
❑
Comment: The septic tank is pumped by a contracted company (Rays) once every two years.
Sand Filters (Low rate)
Yes No NA NE
(If pumps are used) Is an audible and visible alarm Present and operational?
❑
❑
0
❑
Is the distribution box level and watertight?
0
❑
❑
❑
Is sand filter free of ponding?
❑
0
❑
❑
Is the sand filter effluent re -circulated at a valid ratio?
❑
❑
0
❑
# Is the sand filter surface free of algae or excessive vegetation?
❑
0
❑
❑
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
❑
❑
0
❑
Comment: The dosing tank (single bell siphon), distribution box and recirculation tank (single
pump)
were operational and in service. Excessive accumulation of solids was observed on the
sand bed. These solids should be removed and properly disposed.
See "Summary" Section for additional comments.
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Yes No NA NE
•
•
❑
❑
❑
❑
❑
❑
E
Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑
Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑
Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑
Comment: The tablet chlorinator was severely tilted to one side due to structural issues with the metal
supports. The support structure must be repaired as soon as possible. Please be advised
that the subject permit requires the permittee to properly operate and maintain all facilities
and systems of treatment and control at all times [Permit Condition Reference: Part II,
Section C(2) Proper Operation and Maintenancel.
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ ❑
0
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑ ❑
0
❑
Page# 5

Permit: NC0058084 Owner - Facility: Gough Econ WWTP
Inspection Date: 03/12/2019 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use? 4
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
0
❑
Is flow meter calibrated annually?
❑
❑
0
❑
Is the flow meter operational?
❑
❑
0
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: Instantaneous effluent flows are based on the bucket and stop watch method.
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?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The facility was not discharging at the time of the inspection.
Page# 6