NC0071242_NOD-2019-PC-0144_20190604

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Tony Konsul, Regional Manager
Carolina Water Service Inc. of N.C.
Post Office Box 240908
Charlotte, North Carolina 28224
Dear Mr. Konsul:
NORTH CAROLINA
Environmental Quality
June 4, 2019
Subject: Notice of Deficiency
Compliance Evaluation Inspection
Riverpointe Subdivision WWTP
NPDES Permit No. NCO071242
Mecklenburg County
Tracking #: NOD-2019-PC-0144
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
May 24, 2019, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our
findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Deficiency (NOD) due to the facility's failures to properly operate and maintain
the effluent sampler (minimum aliquot volume and tubing cleaning/replacement) and provide access to all components on the
flow measurement system. These are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-
215 as detailed in the Effluent Sampling/Summary and Flow Measurement -Effluent Sections of the attached report.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day
may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of
any permit issued pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State
that may result from the violations.
It is requested that a written response be submitted to this Office by June 25, 2019, detailing the actions taken to address
all above -noted violations. In addition, the response shall also include the findings (by the contracted company) on the
operational status of the backup generator. In responding, please address your comments to the attention of Mr. Wes Bell.
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

Mr. Tony Konsul
Page Two
June 4, 2019
The report should be self-explanatory; however, should you have any questions concerning this report, please do not
hesitate to contact Mr. Bell at [phone] or at wes.bell(�Dncdenr.gov.
Sincerely,
DocuSigned by:
40t4W H P;,Uf
for
F161 F669A2D84A3...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure: Inspection Report

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 NCO071242 111 12 I 19/05/14 I17 18 I S i 19 i G i 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 B1 QA ---------------------- Reserved -------------------
67
2.0 70 Id I 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
I —I u
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)
11:34AM 19/05/14
15/11/01
Riverpointe WWTP
15820 Alloway Ln
Exit Time/Date
Permit Expiration Date
Charlotte NC 28278
01:45PM 19/05/14
20/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Charles Edward Wood/ORC/704-621-9204/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
J Bryce Mendenhall,5701 Westpark Dr Ste 101 Charlotte INC 28217/VP
Operations/704-319-0517/ 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
Wes Bell cSignedeby: MRO WQ//704-663-1699 Ext.2192/ 6/4/2019
E�:'�961D90=437-
Signature�e& of Manag ent95ckWviet%r Agency/Office/Phone and Fax Numbers Date
f fi
Andrew Pitner WQ//704-663-1699 Ext.21 6.4.19
1`16n.uv
.MRO
F161 FB69A2D84A3..
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NC0071242 I11 121 19/05/14 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
EFFLUENT SAMPLING SECTION cont'd:
Monthly sampler aliquot verifications (at a minimum) should be performed and documented. The ORC
and staff must ensure that the preset gallon interval between the collection of the samples is fixed at no
greater than 1/24 of the expected total daily flow at the treatment system (Permit Condition Reference:
Part II, Section A Composite Sample).
Page#

Permit: NCO071242 Owner - Facility: Riverpointe WWTP
Inspection Date: 05/14/2019 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
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
M
❑
❑
❑
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 Division issued a permit modification on 3/14/17 to change several parameters from
weekly average to daily maximum effluent limits.
The last compliance evaluation inspection was performed by Mecklenburg County
Water
Quality Program staff on 5/26/16.
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?
❑
❑
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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on each shift?
Is the ORC visitation log available and current?
❑
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Is the ORC certified at grade equal to or higher than the facility classification?
❑
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Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
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Is a copy of the current NPDES permit available on site?
❑
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Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Page# 3

Permit: NCO071242
Inspection Date: 05/14/2019
Record Keeping
Owner - Facility: Riverpointe WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durina the inspection were oraanized and well maintained. Discharae
Monitoring Reports (eDMRs) were reviewed for the period April 2018 through March 2019.
No effluent limit violations were reported and all monitoring frequencies were correct.
The facility staff must ensure that all ORC and/or Backup ORC visitations are properly
documented on the eDMRs (May 2018).
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# 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? ❑ ❑ 0 ❑
Comment: On -site field analyses (dissolved oxygen, pH, temperature) are performed under Carolina
Water Service, Inc.'s field laboratory certification #5228. K&W Labs (all effluent parameters
except field) has also been contracted to provide analytical support.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected below all treatment units?
0
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❑
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Is proper volume collected?
❑
0
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Is the tubing clean?
❑
0
❑
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# 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
0
❑
❑
❑
representative)?
Comment: The subject permit requires composite and grab effluent samples.
The sampler was not collecting 100 ml. aliquots (approximately 60 mis.) as required by the
Permit (Part II, Section A Composite Sample). In addition, the sampler tubing needed to be
cleaned and/or replaced. Please be advised that the permittee shall at all times properly
operate and maintain all facilities of treatment and control (and related appurtenances)
which are installed or used by the Permittee to achieve compliance with the conditions of
this permit [Permit Condition Reference: Part II, Section C(2) Proper Operation and
Maintenancel. See "Summary" Section for additional comments.
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 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCO071242
Inspection Date: 05/14/2019
Operations & Maintenance
Owner - Facility: Riverpointe WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The facility appeared to be adequately treating the wastewater at the time of the inspection.
Process control measurements are being documented and maintained on -site.
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
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Is the unit in good condition?
0
❑
❑
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Comment:
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
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Is the basin free of excessive grease?
0
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Are all pumps present?
0
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Are all pumps operable?
0
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Are float controls operable?
0
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Are audible and visual alarms operable?
0
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# Is basin size/volume adequate?
0
❑
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Comment:
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
❑ ❑
0
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Are the diffusers operational?
0 ❑
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Is the foam the proper color for the treatment process?
0 ❑
❑
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Does the foam cover less than 25% of the basin's surface?
❑ 0
❑
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Is the DO level acceptable?
0 ❑
❑
❑
Page# 5

Permit: NCO071242
Inspection Date: 05/14/2019
Aeration Basins
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Owner - Facility: Riverpointe WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
❑ ❑ ■ ❑
Comment: Aqueous lime is added to maintain appropriate alkalinity/pH levels.
The solids inventory and sludge age in the aeration basins appeared to need additional
evaluation/adjustment due to the dark appearance of the mixed liquor and foam and the
cloudy supernate of the 30-minute settleability test. Note: Evidence of foam was also
observed in the downstream treatment units including UV system and effluent
pump station.
The ORC/Permittee must ensure that an adequate sludge wasting program is
implemented
(via process control program, etc.) to maintain an appropriate solids inventory
and sludge
age in the aeration basins.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
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❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
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Are weirs level?
0
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Is the site free of weir blockage?
0
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Is the site free of evidence of short-circuiting?
0
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Is scum removal adequate?
0
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Is the site free of excessive floating sludge?
0
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Is the drive unit operational?
0
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Is the return rate acceptable (low turbulence)?
0
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Is the overflow clear of excessive solids/pin floc?
0
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Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
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Comment:
Filtration (High Rate Tertiary)
Yes No NA NE
Type of operation:
Cross flow
Is the filter media present?
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Is the filter surface free of clogging?
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Is the filter free of growth?
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Is the air scour operational?
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Is the scouring acceptable?
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Is the clear well free of excessive solids and filter media?
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Comment: Both filters were operational and in service.
Disinfection - UV Yes No NA NE
Are extra UV bulbs available on site? 0 ❑ ❑ ❑
Page# 6

Permit: NCO071242
Inspection Date: 05/14/2019
Disinfection - UV
Owner - Facility: Riverpointe WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
0
❑
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Is transmittance at or above designed level?
0
❑
❑
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Is there a backup system on site?
0
❑
❑
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Is effluent clear and free of solids?
❑
0
❑
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Comment: The effluent appeared slightly
turbid with evidence of foam in the UV outlet chamber.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
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❑
Is the flow meter operational?
0
❑
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(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: The flow meter is calibrated twice Der vear and was last calibrated on 12/28/18 by B.W
Allen Company. The ORC and staff must ensure that the totalizer readings are consistently
recorded every twenty-four (24) hours.
The flow meter was not able to be inspected without potentially impacting the operation of
the secondary flow measuring device (ultransonic). The cover for the primary flow
measuring device (weir, flume, etc.) should be repaired/replaced to allow for future
inspections. Please be advised that the Permit requires the Permittee to allow for the
inspection of any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this permit [Permit Condition Reference:
Part II, Section D (8) Inspection and Entryl.
Pump Station - Effluent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
0
❑
❑
❑
Are all pumps present?
M
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Are all pumps operable?
0
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Are float controls operable?
0
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Is SCADA telemetry available and operational?
0
❑
❑
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Is audible and visual alarm available and operational?
0
❑
❑
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Comment:
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?
0
❑
❑
❑
Page# 7

Permit: NC0071242
Inspection Date: 05/14/2019
Owner - Facility: Riverpointe WWTP
Inspection Type: Compliance Evaluation
Aerobic Digester Yes No NA NE
# Is the odor acceptable? 0 ❑ ❑ ❑
# Is tankage available for properly waste sludge? 0 ❑ ❑ ❑
Comment: The facility is equipped with an aerobic sludge digester and sludge drying box (both
operational and in service). A contracted company (L&L Environmental) removes sludge on
an as -needed basis.
Standby Power
Yes No NA NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
❑
0
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
0
❑
❑
❑
Is the generator fuel level monitored?
0
❑
❑
❑
Comment: The aenerator is tested weekly (automatically) under load. A contracted comoanv services
(Kraft Power) services the generator twice per year.
The generator would not start at the time of the inspection. The Area Manager is
determining whether or not the generator will activate without being under load by having
Kraft Power evaluate the generator. The Area Manager will notify DWR of the Kraft Power's
findings.
Page# 8