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Home My WebLink AboutNCG590021_Compliance Evaluation Inspection_20190319ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. Ron Sink, CEO / General Manager Davidson Water, Inc. P.O. Box 969 Welcome, NC 27374 NORTH CAROLINA Environmental Quality March 20, 2019 SUBJECT: NOTICE OF DEFICIENCY - Compliance Evaluation Inspection Davidson Water Treatment Plant General Permit - Certificate of Coverage No. NCG590021 Davidson County Dear Mr. Sink: On March 19, 2019, Jenny Graznak of this office met with Craig Koontz, Operator in Responsible Charge (ORC), Charles Minter, Back Up ORC, and Brandon Garner, Superintendent, to perform a Compliance Evaluation Inspection at the Davidson Water Treatment Plant. This type of inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached EPA inspection form details the areas that were evaluated during this inspection. Please note the following items of concern: 1) The inspector noted that the facility has been collecting grab samples instead of 24-hour composite samples for the annual Whole Effluent Toxicity test as required by the permit since 2017. Therefore, this inspection letter is being sent as a Notice of Deficiency. Please make certain that the next test is collected as a composite sample. If you are unable to obtain an entire 24-hour sample due to lack of discharge, simply document how many hours are obtained. 2) According to lab data, the facility failed the February 2019 Whole Effluent Toxicity test. The permit requires the facility must perform testing in each of the following two months after a failed test. It is our understanding that this facility only discharges one month out of each year due to recycled backwash water. Therefore, you are only required to perform the Whole Effluent Toxicity test during typical discharge events. 3) Our office responded to and documented a Fluoride spill that occurred at this facility in February 2019. According to operators, 622 gallons of Fluoride were accidentally released, and some did reach surface waters of the State through a storm drain on site. A separate correspondence from our office was sent regarding this incident. NOAn-icJwaur�nD �\� Qbi� nawmnem of Enmronm wLLumv North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27103 336,776,9800 4) Davidson Water, Inc. also holds General Permit No. NCG520066 for a sand dredging operation that no longer exists. The sediment basin that was originally permitted has been flooded as part of the facility's reservoir system. Therefore, since you no longer require the permit, you should apply for rescission. TO rescind a permit, the facility owner (or authorized representative) should send a letter including the permit number, name and address of the facility, and reason for the rescission request to the NPDES Compliance & Expedited Permit Unit at the address below: Division of Water Resources NPDES Compliance & Expedited Permit Unit 1617 Mail Service Center Raleigh, NC 27699-1617 If you have any questions regarding the inspection or this report, please contact Jenny Graznak or me at (336) 776-9800. Sincerely, DocuSigned by: -,uu� OD2D3CE3F167456_. for Lon T. Snider Assistant Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: Central Files WSRO NPDES Unit 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 NCG590021 111 12 I 19/03/19 I17 18 I S J 19 L G] 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 ------------------- 671 70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80 u ty I I i 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) 10:OOAM 19/03/19 17/10/01 Davidson Water WTP 388 Koontz Rd Exit Time/Date Permit Expiration Date Lexington INC 27295 12:OOPM 19/03/19 19/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles David Minter/ORC/336-479-4441/ David Craig Koonts/ORC/336-248-7691/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Ron Sink,PO Box 969 Welcome NC 273740969/General Manager/336-764-2534/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters 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 3/20/2019 Jennifer F Graznak cusigned by: WSRO WQ//336-771-5000/E�Do 2D3CE3F167456_. Signature of Management i1ed by: Agency/Office/Phone and Fax Numbers Date �^ 14• �� 3/20/2019 OD2D3CE3F167456_. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCG590021 I11 12, 19/03/19 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Please note the following items of concern: 1)The inspector noted that the facility has been collecting grab samples instead of 24-hour composite samples for the annual Whole Effluent Toxicity test as required by the permit since 2017. Therefore, this inspection letter is being sent as a Notice of Deficiency. Please make certain that the next test is collected as a composite sample. If you are unable to obtain an entire 24-hour sample due to lack of discharge, simply document how many hours are obtained. 2)According to lab data, the facility failed the February 2019 Whole Effluent Toxicity test. The permit requires the facility must perform testing in each of the following two months after a failed test. It is our understanding that this facility only discharges one month out of each year due to recycled backwash water. Therefore, you are only required to perform the Whole Effluent Toxicity test during typical discharge events. 3)Our office responded to and documented a Fluoride spill that occurred at this facility in February 2019. According to operators, 622 gallons of Fluoride were accidentally released, and some did reach surface waters of the State through a storm drain on site. A separate correspondence from our office was sent regarding this incident. 4)Davidson Water, Inc. also holds General Permit No. NCG520066 for a sand dredging operation that no longer exists. The sediment basin that was originally permitted has been flooded as part of the facility's reservoir system. Therefore, since you no longer require the permit, you should apply for rescission. TO rescind a permit, the facility owner (or authorized representative) should send a letter including the permit number, name and address of the facility, and reason for the rescission request to the NPDES Compliance & Expedited Permit Unit at the address below: Division of Water Resources NPDES Compliance & Expedited Permit Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Page# Permit: NCG590021 Owner - Facility: Davidson Water WTP Inspection Date: 03/19/2019 Inspection Type: Compliance Evaluation 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: 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? 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: 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 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 Permit: NCG590021 Inspection Date: 03/19/2019 Record Keeping Facility has copy of previous year's Annual Report on file for review? Owner - Facility: Davidson Water WTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ■ ❑ Comment: The faidity uses Environmental Chemists, Inc. in Wilmington for laboratory analysis. Samples are sent via overnight UPS. The operators measure chlorine and pH field parameters under certification # 5537. Lagoons Yes No NA NE Type of lagoons? # Number of lagoons in operation at time of visit? 2 Are lagoons operated in? Series # Is a re -circulation line present? ❑ ❑ 0 ❑ Is lagoon free of excessive floating materials? 0 ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? 0 ❑ ❑ ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? 0 ❑ ❑ ❑ Are dikes free of erosion? 0 ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple 0 ❑ ❑ ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? 0 ❑ ❑ ❑ Is the lagoon free of short circuiting? 0 ❑ ❑ ❑ Comment: De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ M ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Are the tablets the proper size and type? ❑ ❑ 0 ❑ Comment: The facility adds calcium thosulfate as necessary. Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? Comment: Page# 4 Permit: NCG590021 Owner - Facility: Davidson Water WTP Inspection Date: 03/19/2019 Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? N ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: The flow meter was calibrated in March 2018 and is now due for annual calibration. 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: 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 ❑ 0 ❑ ❑ representative)? Comment: The facility has been collecting grab samples instead of 24-hour composite samples for the annual Whole Effluent Toxicity test. If you are unable to obtain an entire 24-hour sample due to lack of discharge. document how manv hours are obtained. Drying Beds Yes No NA NE Is there adequate drying bed space? 0 ❑ ❑ ❑ Is the sludge distribution on drying beds appropriate? ❑ ❑ ❑ Are the drying beds free of vegetation? 0 ❑ ❑ ❑ # Is the site free of dry sludge remaining in beds? 0 ❑ ❑ ❑ Is the site free of stockpiled sludge? 0 ❑ ❑ ❑ Is the filtrate from sludge drying beds returned to the front of the plant? 0 ❑ ❑ ❑ # Is the sludge disposed of through county landfill? ❑ ❑ 0 ❑ Page# 5 Permit: NCG590021 Inspection Date: 03/19/2019 Drying Beds # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Owner - Facility: Davidson Water WTP Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ Comment: EMA visits the facility on an annual basis to pump out lagoons and send sludge to the press on site. Page#