NCG590021_NOD - CEI_20190320

ROY 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.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27103
NONTH CAROI INA '
U ofEWU td �� 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 [phone].
Sincerely,
E0oeu819 d by:
OD2D3CE3F1B7458...
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
UPa,M'it'„

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance IrlspeCtlon 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 1 2 I5 1 3 I NGG590021 I11 12 19/03/19 17 18 I c I 19 I c. I 201I
_1
211
1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 I III I l66
I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIA Reserved
67 70I j 71.Lj 72 � ti �. 73I � I74 75 80
LJ LJ L1J
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)
10:OOAM 19/03/19
17/10/O1
Davidson Water WTP
388 Koontz Rd
Exit Time/Date
Permit Expiration Date
Lexington NC 27295
12:OOPM 19/03/19
19/07/31
Name(s) of Onsite Representative(s)mties(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 E Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N 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
Jennifer F Graznak eusigned by: WSRO WQ//336-771-5000/
3/20/2019
,�ti.k-
^O -^
E�Do
2D3CE3F787456...
Signature of Management ti§Wed by:' Agency/Office/Phone and Fax Numbers Date
�4• 3/20/2019
' O=3CE31`167456...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 1 NCG590021 12 19/03/19 17 18 j n
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#

Pennit: 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 ❑ ❑ 0 ❑
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? °
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: -
Record Keepinq
Yes No NA NE
Are records kept and maintained as required by the permit?
M
❑
❑
❑
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?
❑
❑
❑
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?
❑
110
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
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
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?
0
❑
❑
❑
Page# 3

Permit: NCG590021 Owner - Facility: Davidson Water WrP
Inspection Date: 03119/2019 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: The faiclity 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
Type of lagoons?
# Number of lagoons in operation at time of visit?
Are lagoons operated in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes clear of woody'vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
Is the lagoon surface free of weeds?
Is the lagoon free of short circuiting?
Comment:
De -chlorination
Type of system ?
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?
Are the tablets the proper size and type? ,
Comment: The facilitv adds calcium thosulfate as necessary.
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Yes No NA NE
E
Series
❑ ❑ M ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
M ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
Yes No NA NE
Liquid
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ M ❑
❑ ❑ ■ ❑
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?
M
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
M
❑
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? M ❑ ❑ ❑
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?
❑
❑
❑
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
❑
❑
M
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
M
❑
❑
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 many 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?
�.
❑
❑
❑
# Is the site free of dry sludge remaining in beds?
M
❑
❑
❑
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
Owner -Facility: Davidson WaterWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
# Is the sludge land applied? 0 ❑ ❑ ❑
(Vacuum filters) Is polymer mixing adequate? ❑ ❑ ❑
Comment: EMA visits the facility on an annual basis to pump out lagoons and send sludge to the press
on site.
Page# 6