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Home My WebLink AboutNC0021369_NOV-2019-PC-0238 CEI_20190404DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 ROY COOPER G(vrrflcu IMICHAEL S. RECAN Secretary LINDA CULPEPPER aiiC f r Certified Mail #7017 2620 0000 9759 1000 Return Receipt Requested NORTH CAROLINA Environmental Quality April 04, 2019 Tim Barth, Manager Town Town of Columbus PO Box 146 Columbus, NC 28722 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2019-PC-0238 Permit No. NCO021369 Columbus WWTP Polk County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Columbus WWTP on March 25, 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. NC0021369. 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 violation(s) were noted during the inspection: Inspection Area Description of Violation Aeration Basins Facility solids are not being adequately removed from the system. The AB is not operating optimally due to significant solids build-up within the basin and throughout the facility. See the attached inspection report for further details. Permit Standard Conditions Section C.2 requires the permittee to properly operate and maintain all facilities and systems of treatment which are installed to achieve compliance. North CaroiinsDepsrtmentof -EnvironmentaIQualrty I Division ofWsterResouroes AshevO— Reg?onalOffsce 1 2090 U.S. 70Hthxray I Swaananos, North Csroim 23773 823T36-45DO DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 In addition, the issues below must also be addressed: Sheet Curtain Wall: The curtain wall at the far end of the aeration basin is structurally compromised. This should be assessed and addressed as soon as possible to prevent complete structural failure. Solids: As briefly addressed above in the violation, solids handling, and storage also needs to be assessed. Drain: Please verify the drain within calcium thiosulfate building discharges back into the plant and not into the environment. 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, please respond in writing (email is acceptable) to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. 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, DocuSigned by: EN. 775374DO. For 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 Chris Cochran, ORC James Smith, Public Works Director G:\WR\WQ\Polk\Wastewater\Municipal\Columbus WWTP 21369\Inspections\Inspect. March 25, 2019\20190404_NC0021369_NOV2019PCO238 North CaroiinaDepsrtnientof -Environmenta;Quai!ty I D;usionofWsterResouroes Ashev,; a Region$:-Jff:ce 1 2090 U.S. 70Ngh -W I Swannanos, North Csro:ins 23773 ° `. 823K96-45DD DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 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 IF I 3 I NC0021369 111 12 I 19/03/25 I17 18 I S J 19 L G] 201 I 211111 I I I I I I II I I I I I I I I I I I I I 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 131 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 I� 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 19/03/25 14/03/01 Columbus WWTP 355 Levi Rd Exit Time/Date Permit Expiration Date Columbus NC 28722 12:OOPM 19/03/25 18/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Christopher C Cochran/ORC// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert K Rosseter,515 Forest Ave Landrum SC 293569406//864-848-5527/ 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 Mikal Willmer Ds Division of Water Quality//828-296-4686) 4/4/2019 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date D^o�s�e^ea nv. 4/4/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 NPDES yr/mo/day Inspection Type (Cont.) NCO021369 I11 121 19/03/25 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Columbus WWTP on March 25, 2019. This inspection was conducted to determine whether the facility is being operated and maintained within compliance of NPDES Permit No. NC0021369. Chris Cochran (ORC), Ricky McGuinn (Backup ORC) and James Smith (Public Works Director) assisted in the inspection. Staff are operating the facility to the extent conditions will allow. There were several items noted at the time of the inspection that need to be addressed to bring the system back into compliance and optimal performance based on the current equipment installed. Headworks: No major issues were noted at the headworks of the facility. Staff report they plan to replace the screens on the screw auger. There is potentially a grade issue with the main aerial line coming into the facility. This should be assessed in future collection system projects. Aeration Basin: Several major issues noted during the inspection. Staff report approximately 10 years ago the basin's solids depth was assessed and found to be approximately half the total basin depth. It was suggested and recommended in 2006 the basin be hydraulically assessed. A special permit condition was added in the 2008 permit to hydraulically assess the basin within 180 days, but there is no current record on file that indicates an assessment was submitted. The engineering assessment by WK Dickson in 2011 noted solids removal and rehabilitation of the aeration basin should be included as part of the Town's WWTP upgrade; however, records on file do not indicate this ever occurred as part of the update. At the time of the inspection, solids had accumulated to the point a solid mat was forming on the edge of the basin closest to the headworks. Facility staff do not have a means to check solids depth without a boat. The significant number of solids is contributing to the excessive foam, growth of algae and short circuiting through the basin. Aerators are set on timers; however, due to the solid's accumulation, the aerators must be kept on most of the day to maintain an appropriate DO level for treatment. Additionally, one of the aerators is currently down and creating a dead spot near where flow exits the aeration basin. Curtain Wall: The aeration basin was subdivided during improvements in 1987 when flows reduced, and the other end of the basin was used as a sludge holding pond. In 2011 facility staff reported approximately 300,000 gallons of sludge had accumulated in the holding pond and were potentially leaking back into the aeration basin. As of 2019, the curtain wall is compromised structurally and should be addressed as soon as possible. The curtain wall failing would potentially shut -down the WWTP should all the solids and material comingle with the already overloaded aeration basin. Clarifiers: The second clarifier was recently repaired and brought back -online. Due to the digester being at or near capacity, staff are unable to waste as much as needed. The sludge blankets are elevated in clarifiers 1 & 2(over 50% of total depth) and solids and pin floc are beginning to pass over the effluent weirs. Aerated Sludge Holding Tank/Digester: Digester is at capacity and staff must decant frequently to waste from the clarifiers. This is partially due to the wet weather and being unable to land apply; however, additional solids are potentially leaving the aeration basin, due to the reduced detention time, and having to settle out in the clarifiers, further increasing the need to waste more. Chlorine Contact Chamber & Declhorination: Chamber appeared free of significant solids. Staff have a pump within the dechlorination building used to remove solids from the contact chamber. Staff mentioned potentially creating more contact time for dechlor or changing the feed distribution to reduce residuals further. Currently chlorine and dechlor are flow proportional. Staff may also wish to further Page# DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NC0021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation assess the strength and feed volume of the calcium thiosulfate. Dechlorination Building: A floor drain is directly next to the calcium thiosulfate solution within the dechlorination building. Please verify this drain discharges within the facility and not to the environment. Solids Storage: The Town may want to consider an additional aerobic digester to allow for adequate wasting, even during extremely wet years. Page# DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NCO021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation Grit Removal Type of grit removal (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? a.Manual # Are there any special conditions for the permit? b.Mechanical Is the grit free of excessive organic matter? Is access to the plant site restricted to the general public? Is the grit free of excessive odor? Is the inspector granted access to all areas for inspection? # Is disposal of grit in compliance? Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Facility submitted renewal application in February of 2018. New permit is currently under review. Equipment list needs to be updated to reflect current facility. Additional information is being submitted by the new ORC, Chris Cochran. Please continue to use the expired permit until the new permit has been finalized and issued. Comment: Vortex grit removal system. No obvious issues or odors noted at the headworks. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ 0 ❑ ❑ Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Is proper volume collected? ❑ ❑ ❑ Comment: The facilitv arounds are beina well maintained. DH. temoerature. DO. chlorine residuals and sludge fudge readings are analyzed. 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 sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: Portable sampler is utilized at the headworks. Composite times are recorded on daily log -L,- ..- ---:4- Record Keeping Yes No NA NE Page# 4 DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NCO021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation 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? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Surface Is the basin free of dead spots? ❑ 0 ❑ ❑ Are surface aerators and mixers operational? ❑ 0 ❑ ❑ Are the diffusers operational? ❑ ❑ 0 ❑ Is the foam the proper color for the treatment process? ❑ 0 ❑ ❑ Does the foam cover less than 25% of the basin's surface? ❑ 0 ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ 0 ❑ Comment: There are several issues that need to be addressed within and near the Aeration Basin. See summary for details. Page# 5 DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NCO021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation Aeration Basins Aerobic Digester 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? Yes No NA NE Yes No NA NE ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ Comment: Capacity may be adequate for wastinq and storage when land application events can occur regularly; however, there is currently very little capacity to waste as needed. See summary for additional details. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) ❑ ❑ ❑ Comment: Secondary clarifiers did not have excessive floatina sludae: however. there was sianificant pin floc within the effluent launder of clarifier #2. The sludge blankets were approximately 7' out of 10' and 10' of 13' for clarifiers 1 & 2 respectively. See summary for further details. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? 0 ❑ ❑ ❑ Comment: All RAS/WAS pumps are currently operational. Disinfection -Gas Are cylinders secured adequately? Yes No NA NE ■ ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NCO021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation Disinfection -Gas 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 Ibs 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? Yes No NA NE ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Empty chlorine gas cylinders are stored outside the chlorination building. Full cVlinders are stored inside. The Town may wish to consider some form of cover for the empty cylinders since the sun can compromise the integrity of the container. De -chlorination Yes No NA NE Type of system ? Liquid 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? E ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ 0 ❑ Comment: Liquid dechlor (calcium thiosulfate) is used. Feeds are flow proportional. There is a drain within the dechlor building that should be addressed. See summary for details. Are tablet de -chlorinators operational? ❑ ❑ 0❑ Number of tubes in use? 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? ❑ ❑ ❑ Comment: Staff report the totalizer works and the flow chart is accurate: however, the continuous reading on the flow meter no longer displays correctly. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: 2DFAA3B5-682D-4D17-A391-97AAD4076374 Permit: NCO021369 Owner - Facility: Columbus WWTP Inspection Date: 03/25/2019 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE 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 M ❑ ❑ ❑ representative)? Comment: Recommend the tubing be replaced to the sampler. The tubing can be covered to reduce growth. 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: No apparent visual impacts noted to the stream at the time of the inspection. Page# 8 Docu5�". 6 S E C U R E 6 Certificate Of Completion Envelope Id: 2DFAA3B5682D4Dl7A39197AAD4076374 Status: Completed Subject: Please DocuSign: 20190404_NC0021369_NOV2019PCO238.draft. docx, 20190404_NCO021369_NOV2019PCO238 ... Source Envelope: Document Pages: 10 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 1 Mikal Willmer AutoNav: Enabled 217 W. Jones Street Envelopeld Stamping: Enabled Raleigh, NC 27699 Time Zone: (UTC-05:00) Eastern Time (US & Canada) Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Holder: Mikal Willmer Location: DocuSign Apr 4, 2019 1 09:22 Mikal.willmer@ncdenr.gov Signer Events Signature Timestamp Mikal Willmer DS Sent: Apr 4, 2019 1 09:23 mikal.willmer@ncdenr.gov Viewed: Apr 4, 2019 1 09:23 Environmental Specialist Signed: Apr 4, 2019 1 09:24 North Carolina Department of Environmental Quality Security Level: Email, Account Authentication Signature Adoption: Drawn on Device (None) Using IP Address: 149.168.204.10 Electronic Record and Signature Disclosure: Not Offered via DocuSign Zan Price ED—Sign1d by: Sent: Apr 4, 2019 1 09:24 zan.price@ncdenr.gov Viewed: Apr 4, 2019 1 09:24 DWR-RO 627BID277537400... Signed: Apr 4, 2019 1 09:24 DEQ Security Level: Email, Account Authentication Signature Adoption: Pre -selected Style (None) Using IP Address: 149.168.204.10 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 Apr 4, 2019 1 09:24 Certified Delivered Security Checked Apr 4, 2019 1 09:24 Signing Complete Security Checked Apr 4, 2019 1 09:24 Completed Security Checked Apr 4, 2019 1 09:24 Payment Events Status Timestamps