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Home My WebLink AboutNC0021491_Compliance Evaluation Inspection_20190327ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA EnwronmentalQuaUty CERTIFIED MAIL # 7015-0640-0005-8164-0285 RETURN RECEIPT REQUESTED March 27, 2019 Mr. Will Marklin, Mayor Town of Mocksville 171 S Clement St. Mocksville, NC 27028 VV& Nr� 012019 Wato, "�a �rrnif�a urces ng Section SUBJECT: Compliance Evaluation Inspection and Notice of Violation NOV-2019-PC-0202 Dutchman Creek WWTP NPDES Permit No. NCO021491 Davie County Dear Mr. Marklin, On March 5, 2019, Kelli Park of this office, met with Todd Robinson; ORC, Chip White; backup ORC, and Chris Bitterman to perform a Compliance Evaluation Inspection at the Dutchman Creek wastewater 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. Violations and areas of concern observed from the inspection are described below. 1) The influent and effluent samplers are currently set up to pull a time proportionate sample. Via the permit, composite samples must be flow proportional. Please address this immediately. 2) The effluent flow meter and one of the three influent flow meters has not been calibrated this year. It is a permit requirement to have them calibrated yearly. Please address this immediately. 3) The weirs on the first clarifier were not level. Most of the flow was going out of only one side of the weirs in that clarifier. 4) The circular well in the clarifiers had a significant sludge build up. It is suggested that these are cleaned out more often. There was also floating sludge and pin floc in the clarifiers, making the water cloudy. f Dutchman Creek WWTP CEI / NOV 312019 5) It appeared that there was short circuiting occurring. More flow was going into the first aeration basin and clarifier than the other two parallel units. Please address this to get the flow into the three units more equal. The uneven weirs on the connected clarifier are further evidence of short circuiting in this train. 6) It is suggested that when sludge is pumped from the digester that records are recorded stating the date and how much was pumped. 7) It is suggested that when the town maintains and checks the influent pump station that a log is kept with detailed information about the visit. Please reply in writing to this letter within 10 business days of receiving it. Your written reply should address each of the noted deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. Your response will be considered in any further enforcement actions. If you have any questions regarding the inspection or this report, please contact Kelli Park or me at (336) 776-9800 or by email at kelli.parka-ncdenr.gov or Ion.snider(a)-ncdenr.gov. Sincerely, CDawSlpned by: L-0. SMxcr 146ME225C94EA . Lon Snider Assistant Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: Central Files WSRO ,N,PDES Unit Page 2 of 2 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 ) 2 Is I 3 I N00021491 I11 , 12 19/03/05 17 18 I' I 19 I c I 201 I 21111111111111111111111111111111111111111111 f6 I Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIAReserved 67 70LJ 71 72 nJ 73174 751 I I I I I I80 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 permit Number) 11:00AM 19/03/05 14/11/01 Dutchman Creek WWTP 295 Garwood Rd Exit Time/Date Permit Expiration Date Mocksville NC 27028 01-00PM 19/03/05 19/06/30 Name(s) of Onsite Representative(s)/Tifles(s)/Phone and Fax Number(s) Other Facility Data Todd Franklin Robinson/ORC/704-881-4598/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Christine W Bralley,171 S Clement St Mocksville NC 27028//336-753-6701/3367519187 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 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 Kelli A Park WSRO WQ//336-776-9689/ WL Vcj_� -3 /nl n Signature of ManageemenntgQMAd a viewer Agency/Office/Phone and Fax Numbers Date LGA, T SMxer 3/27/19 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) 31 NCO021491 I1 12 19/03,05 17 18 I c l Section D• Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On March 5, 2019, Kelli Park of this office, met with Todd Robinson; ORC, Chip White; backup ORC, and Chris Bitterman to perform a Compliance Evaluation Inspection at the Dutchman Creek wastewater 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. Violations and areas of concern observed from the inspection are described below. 1) The influent and effluent samplers are currently set up to pull a time proportionate sample. Via the permit, composite samples must be flow proportional. Please get this fixed immediately. 2) The effluent flow meter and one of the three influent flow meters has not been calibrated this year. It is a permit requirement to have them calibrated yearly. Please get this done immediately. 3) The weirs on the first clarifier were not level. Most of the flow was going out of only one side of the weirs in that clarifier. Please get the weirs evenly leveled. 4) The circular well in the clarifiers had a significant sludge build up. It is suggested that these are cleaned out more often. There was also floating sludge and pin floc in the clarifiers, making the water cloudy. 5) It appeared that there was short circuiting occurring. More flow was going into the first aeration basin and clarifier than the other two parallel units. Please try to get the flow into the three units more equal. The uneven weirs on the connected clarifier are further evidence of short circuiting in this train. 6) It is suggested that when sludge is pumped from the digester that records are recorded stating the date and how much was pumped. 7) It is suggested that when the town maintains and checks the influent pump station that a log is kept with detailed information about the visit. Please reply in writing to this letter within 10 business days of receiving it. Your written reply should address each of the noted deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. Your response will be considered in any further enforcement actions. If you have any questions regarding the inspection_or this report, please contact Kell! Park or me at (336) 776-9800 or by email at kelli.park@ncdenr.gov or lon.snyder@ncdenr.gov. Page# I- Permit NCO021491 Owner -Facility: Dutchman CreekWWTP Inspection Date: 03/05/2019 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 M ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The permit expires in June of 2019. They submitted for renewal in December of 2018. 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 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? 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)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 01 ❑ ❑ ❑ Is the chain -of -custody complete? - M ❑ ❑ ❑ 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 2417 with a certified operator ❑ ❑ M ❑ on each shift? Is the ORC visitation log available and current? M ❑ ❑ ❑ 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? M ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑ Page# 3 Permit: NCO021491 Owner -Facility. Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Statesville Analytical is used for water sample analysis. Chlorine, PH, and dissolved oxygen meters have been calibrated within the past year. They recently purchased a new temperature probe, but will have it calibrated next year. pH standards were current. Flow Measurement - Influent 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: 1 of the 3 influent samplers has not been calibrated in the past year. The 2 that have been calibrated are new and were calibrated when they were set up. Please pet the one meter calibrated immediately. SCADA used for continuous recording. Influent flow meter is used for flow data. Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures'? 0 ❑ ❑ ❑ Is the wet well free of excessive grease? N ❑ ❑ ❑ Are all pumps present? N ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? N ❑ ❑ ❑ Is SCADA telemetry available and operational? M ❑ ❑ ❑ Is audible and visual alarm available and operational? 0 ❑ ❑ ❑ Comment: There is no maintance loq, it is suqqested that when the station is checked over and tested that records are recorded. The ORC reported that the town checks the pump twice a month. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ M ❑ ❑ Is sample collected above side streams? ❑ ❑ ❑ Is proper volume collected? M ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ Page# 4 ti a Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation Influent Sampling Yes No NA NE # 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? ❑ ❑ ❑ Comment: Via the permit the influent sampler must be set up to be flow proportional. Please get this fixed immediately. Currently the sampler is set up to pull a 150ml sample every 30 minutes. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanlcal Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Comment: Debris are dried and then disposed of in a dumpster which is taken to the landfill. Aeration Basins Mode of operation Type of aeration system 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/1) Comment: More flow goes into the first aeration basin and the first clarifer than the other two, suggesting that there is short circuting occuring. El • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Ext. Air Surface ❑ ❑ ❑ E ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ E The ORC reported that the dissolved oxygen (DO) is maintained around 5-6 mg/I in the aeration basins. He claims that the plant operates better with a higher DO, and that ammonia spikes if DO goes below 3mg/I. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? E ❑ ❑ ❑ Page# 5 } Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation Secondary Clarifier 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? Is the site free of excessive floating sludge? Is the drive unit operatlonaP Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level, acceptable? (Approximately % of the sidewall depth) Yes No NA NE ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Circular clarifier well contained a lot of built up sludge In all three clarifiers It is suggested that they be cleaned out more often. There was some On floc in all of the clarifiers_ Clarifier 1 had some floating sludge build u as well. The water In all three clarifiers were cloudy the day of inspection It was reported to be due to I&I. According to the ORC about 900,000 gallons had come in the day before the inspection, when the Plant typically gets about 400,000 gallons. Clarifier 3 did not have a circular well due to being a different design. There was however, sludge build up in the equivalent section. The sludge depth in clarifier 1 was 4ft. clarifer 2 was 3 ft, and clarifier 3 was 3ft. More flow goes into the first aeration basin and the first clarifer than the other two, suggesting that there is short circuting occuring. The first clarifier's wiers were not level. It is expected that construction on a new, larger, clarifier is begun within the next few months. Disinfection -Gas 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 Ibs of Chlorine (CAS No. 7782-50-5)? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ M ■ ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ M ❑ Page# 6 Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation Disinfection -Gas Yes No NA NE If yes, then is there a Risk Management Plan on site? ❑ ❑ S ❑ If yes, then what is the EPA twelve digit ID Number? (1000- If yes, then when was the RMP last updated? Comment: The plant has less than 2500 Ibs of chlorine. There is about 1000 Ibs of chlorine on site. About 14-15lbs of chlorine are used each day. De -chlorination Yes No NA NE Type of system ? Gas Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ 0 ❑ ❑ Is storage appropriate for cylinders? N ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ 0 ❑ Comment: Sulfur dioxide gas is used. About 291bs of gas are used each day. Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? 0 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? E ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? N ❑ ❑ ❑ Comment: The effluent flow meter has not been calibrated in the past year. Please get this done immediately. Effluent meter is used for chlorine management. Influent meter is used for flow data. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ 0 ❑ ❑ Is sample collected below all treatment units? E ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? - E ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Page# 7 Permit NCO021491 Owner -Facility: Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type ❑ M ❑_ ❑ representative)? Comment: The effluent sampler was set to pull a sample at a time base rather than flow proportional. Please fix this immediately. The sampler is currently set up to pull a 150 ml every 30 minutes. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? M ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? M ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M❑ Comment: Effluent was clear at the time of inspection. Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ 0 ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming In the tank? M ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? ❑ ❑ ❑ Comment: The digestor is small, resulting in the plant havinq to bag the sludge in large dewatering_ bags. A larger digestor is planned to be built starting sometime this year to aid in sludge handling. Currently 4 dewatering baps are being used. Sludge is handled by EMA resources. The yearly report was available on site for review. It is suggested that each time EMA pumps sludge a record is maintained with the date, who pumped the sludge, and how much was pumped. Sludge is land applied under permit W00003351. There has been no recent land application due to the wet conditions. Standby Power 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? Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ M ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 8 Permit NCO021491 Owner -Facility: Dutchman Creek WWTP Inspection Date: 03/05/2019 Inspection Type: Compliance Evaluation 'Standby Power Yes No NA NE Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: The generator is tested once a week via an auto start. It is tested under load once a month, and the town keeps records of its testing. The town is responsible for checking and maintaining the fuel levels. - The SCADA logs when the generator turns on. The generator was not tested at the time of inspection due to the town maintaining the key to get into it. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? M ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? N ❑ ❑ ❑ # Is the facility using a contract lab? M ❑ ❑ ❑ # 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? ❑ ❑ N ❑ Comment: Page# 9