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Home My WebLink AboutNC0026697_NOD-2019-PC-0137_20190603 June 3, 2019 Certified Mail# 7017 2620 0000 9759 1284 Return Receipt Requested Dakota Ingram Clay County Water & Sewer District PO Box 838 Hayesville, NC 28904 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2019-PC-0137 Permit No. NC0026697 Clay County WWTP Clay County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Clay County WWTP on May 20, 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. NC0026697. 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 deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Effluent sampler is set to constant time/constant volume. Per Part II Section A, constant time/constant volume effluent sampling is only allowed with prior Division approval and if it can be demonstrated flows vary <15%. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Please notify our office, in writing (email is acceptable), within the next 30 days of the District’s plans to address the noted deficiency. Flow proportional effluent sampling is required by permit. As stated above, constant time/constant volume effluent composite sampling is only allowed with prior Division approval and if the permittee can demonstrate flows do not vary by more than 15%. 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 828-296-4686. Sincerely, 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 G:\WR\WQ\Clay\Wastewater\Municipal\Clay County WWTP 26697\Inspections\Inspect. May 20, 2019\20190603_NC0026697_NOD2019PC0137 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0026697 19/05/20 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Clay County WWTP NCSR 1300 Hayesville NC 28904 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 19/05/20 17/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jeremy E Arrowood/ORC/828-389-1361/ Other Facility Data 12:30PM 19/05/20 22/08/31 Name, Address of Responsible Official/Title/Phone and Fax Number Dakota Ingram,PO Box 838 Hayesville NC 28904//828-889-1361/Contacted 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 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 Division of Water Quality//828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 6/3/2019 6/3/2019 NPDES yr/mo/day 19/05/20 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Inspector Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Clay County Water & Sewer District's WWTP. This inspection was condcuted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0026697. Overall the facility is well operated and maintained; however, there was a noted deficiency with the method of effluent sampling. It was mentioned in the previous compliance inspection that effluent sampling needed to be switched to flow proportional or a variance requested. At the time of the most recent inspection, the effluent sampler was still set to time composite. Per Part II Section A, Composite Sampling of the Standard Conditions, effluent sampling must be flow proportional. Constant Time/Constant Volume composite effluent sampling is only allowed with prior Division approval and if the permittee can demonstrate flows do not vary by more than 15%. No other permit deficiencies were noted at the time of the inspection. The following are observations and recommendations. Headworks: The current influent bar screen spacing allows significant debris to pass into the aeration basin. Recommend assessing an alternative setup as budget allows. Safety: There is no easy access to the Aeration Basin diffusers for routine maintenance. Facility staff either must use an extension ladder or walk along the concrete edge of the basin. This presents a significant fall/trip hazard. Standby Power: There is only one portable generator onsite to service the WWTP and 10 lift stations. It is highly recommended the District budget for additional generators in the event of an extended power outage or severe weather. NC0026697 17 (Cont.) Page#2 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Staff routinely check MLSS. Monitor DO and check clarify sludge depth occasionally.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? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Permit has DO reopener and requirement for total mercury analysis within 12 months of permit expiration. Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? 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? 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 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? Copies of the annual report are mailed to customers. They are also posted at the library and post office. The District is looking to post the annual report on the new website. Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical 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? Facility has a small manual bar screen with wide grates and no grit chamber. Mr. Arrowood places a smaller manual screen over the bar screen on occasion to help reduce excessive pass-through debris; however, this backs up the flow at the headworks. Screen is raked and cleaned daily. Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is sampling performed according to the permit? Sampler is set to time composite.Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused 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? Page#4 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Aeration Basins Yes No NA NE Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/l) Diffusers only run along one side of the Basins. Two diffusers were inoperable (reportedly clogged) at the time of the inspection; however, this did not appear to be creating significant dead spots. Mr. Arrowood states the DO is about 1 mg/L during the summer months. Blowers run continuously during the summer and some valves are closed during the winter. Pass-through debris could be seen in the aeration basin. Catch baskets above the basin's discharge collects any debris/grit. These are cleaned once a day. Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 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 operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth) These are AeroMod clarifiers with airlift RAS pumps. Weirs are below the water level so cannot be easily evaluated. Sludge depth stays about 3' to 4' out of 16'. RAS runs off and on throughout the day. Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? System utilizes air-lift pumps. Staff report spare parts are maintained on-site.Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? Page#5 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Aerobic Digester Yes No NA NE # Is tankage available for properly waste sludge? Staff report there is adequate digester space to waste sludge. The digester is settled approximately twice a year and solids are pressed and sent to a Landfill in Georgia. Comment: Disinfection-Gas Yes No NA NE 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 lbs 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? Staff would like to switch to a liquid chlorine feed or another alternative disinfectant for safety reasons. The fire department is notified in the event of a leak. Comment: De-chlorination Yes No NA NE Type of system ?Gas 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? Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? Sulfur dioxide and Chlorine are stored in same building.Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Page#6 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Facility utilizes a siemens flow meter (model has been discontinued).Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Facility's effluent sampler is set to time composite. The District has an ISCO composite sampler and Siemens flow meter which may be incompatible. Staff will check compatibility. Time-composite sampling is only allowed with prior Division approval and if flows only vary < 15%. Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Sampling points are 100' upstream and downstream. Staff report no issues with access to sampling points. Comment: Standby Power Yes No NA NE 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? Is the generator fuel level monitored? Page#7 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Permit:NC0026697 Inspection Date:05/20/2019 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Standby Power Yes No NA NE Portable generator kept at the WWTP can run the entire facility. Generator was recently used to run the facility during a power outage. Fuel is maintained onsite and the District has a contract with Parker Oil located in Hayesville. See summary for generator recommendations. Comment: Solids Handling Equipment Yes No NA NE Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Facility presses the biosolids and hauls to a landfill in Georgia twice a year.Comment: Page#8 DocuSign Envelope ID: 55CDF2BA-37DC-449C-B4FB-7181435DE5A7 Certificate Of Completion Envelope Id: 55CDF2BA37DC449CB4FB7181435DE5A7 Status: Completed Subject: Please DocuSign: 20190603_NC0026697_NOD2019PC0137.docx, 20190603_NC0026697_inspect.pdf Source Envelope: Document Pages: 10 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 1 Mikal Willmer AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Jun 3, 2019 | 10:13 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Jun 3, 2019 | 10:14 Viewed: Jun 3, 2019 | 10:14 Signed: Jun 3, 2019 | 10:15 Electronic Record and Signature Disclosure: Not Offered via DocuSign Zan Price zan.price@ncdenr.gov DWR-RO DEQ Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Jun 3, 2019 | 10:15 Viewed: Jun 3, 2019 | 10:25 Signed: Jun 3, 2019 | 10:25 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 Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Jun 3, 2019 | 10:15 Certified Delivered Security Checked Jun 3, 2019 | 10:25 Signing Complete Security Checked Jun 3, 2019 | 10:25 Envelope Summary Events Status Timestamps Completed Security Checked Jun 3, 2019 | 10:25 Payment Events Status Timestamps