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HomeMy WebLinkAboutNC0057193_NOV2019PC0253 RESP_20190521May 21, 2019 G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ Re: NOV-2019-PC-0253 Dear Sir: In response to Notice of Violation 2019-PC-0253 the following corrective actions have been implemented and others are ongoing: Flow measurement - The flow meter is now calibrated and documented as required. Effluent Sampling -The effluent composite sampler was repaired and operational by March 27th 2019. Effluent Sampling -The composite sampler is currently operating in constant time/constant volume mode. The flow meter cannot interface with the sampler. A memo has been sent to John Hennessy to determine if permission to operate in the current configuration is possible. We have started the process of requesting price quotations in the event that the flow meter must be replaced. If a replacement is necessary the meter could be installed as soon as the components could be sourced. The following issues were noted in the inspection report: A ruler is recommended for flow meter calibration. A ruler or other method to accurately measure the head level in the V-notch weir will be used. All maintenance and process control checks should be documented in the log book. Solids pumping should be documented. All maintenance, process control checks, and solids pumping is now being documented in the log book. The audible/visual alarms were not working on the influent and post equalization pump stations. The influent alarms are operating as required. The post equalization pump control requires additional equipment to make the alarms operational, the operator is in the process of ordering and installing that equipment. The repairs will be performed as soon as the materials are delivered and time permits. Safety: 1. The ORC uses an extension ladder to access the reactor for sludge judge measurement. The operator will use the approved ladder to access the reactor for all 0&M purposes. 2. The ORC uses a hose to remove foam from the reactor. The hose extends across the walkway between the reactor and the digester. The operator will make improvements to the foam removal system to prevent safety hazards. Recommendations: 1. Plywood extensions have been added to the chlorine contact basin baffles to prevent short circuiting. The existing chlorine contact chamber operates well. It may perform adequately without the plywood baffles that were installed in 2000. The facility management approved replacement of the plywood baffles with aluminum plate prior to the inspection because the plywood is deteriorated. The present arrangement allows the facility to operate in compliance with a minimum of chlorine and de -chlorinating chemicals. We can replace the baffles with aluminum plate or completely remove the baffles. 2. Assess solids management in the facility, settleable solids test showed approximately 850ml-900m1. The facility has a high percentage of flow from restaurants. The system experienced unusually high traffic for the winter season resulting in more than usual flow from the restaurant. Nocardia bacteria was responsible for the slow settleable solids test. A sludge judge test showed that the solids in the reactor were well within acceptable levels before discharge. The inspector observed a discharge for the SBR reactor that was well within compliance. The grease trap pumping program was increased in March from every 6 weeks to every 4 weeks. The plant was operating well during the seasonal transition period where flow and temperature are changing. Since the inspection Nocardia foaming has decreased. 3. Evaluate the capacity of the digester. The digester capacity is 20,000 gallons. High organic loading in peak season requires that we pump concentrated solids often. Approximately 4000 gallons of sludge is removed every two weeks. This pumping rate decreases throughout the late summer and fall and increases in the mid spring. The ORC will be working with the regional staff to bring the facility into and maintain compliance. The unresolved issue of the flow meter/sampler interface should be resolved as soon as we hear from Mr. Hennessy. Until that time the ORC will continue to address the above issues in an expedient manor. Sincerely, Lance Ingram SRC Nantahala Outdoor Center CC:illiam Irving ev Price JcSEhn Hennessy