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HomeMy WebLinkAboutWQ0004910_NOD-2019-PC-0183_20190816ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Robert Collier, Public Works Director Town of Woodland PO BOX 297 Woodland, NC 27897 Mr. Collier, NORTH CAROLINA Environmental Quality August 16, 2019 Subject: NOTICE OF DEFICIENCY NOD-2019-PC-0183 Compliance Evaluation Inspection Town of Woodland Wastewater Irrigation System Permit Number WQ0004910 Northampton County On August 15, 2019, Rick Trone, Zach Thomas, and Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation inspection of the wastewater irrigation system for Town of Woodland. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, the cooperation and assistance of Mr. M.E. Lassiter, and Ms. Jessica Griffey was helpful and appreciated. This compliance evaluation inspection consisted of the following: • Review of the permit; • Review of the owner/facility information; • Review of ORC logbooks, calibration documentation, Non -discharge wastewater monitoring reports (NDMR), Non -discharge application reports (NDAR), Compliance Monitoring Forms (G W-59) and; • On -site inspection of treatment components and spray fields The current permit was issued October 7, 2016 and expires on September 30, 2021. Currently, Mr. Lassiter is designated ORC with Christopher Wheeler as backup ORC. Ms. Griffey is currently slated to become ORC soon. Components of the wastewater system appeared to be overall well -maintained and operational. Water in the primary and storage lagoon was free of floating solids and plenty of freeboard was available in the storage lagoon. The primary lagoon has a significant amount of solids and debris which reduces capacity. D Q ,, North Carolina Department of Environmental Quality I Division of Water Resources �/� Raleigh Regional office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 Mr. Lassiter explained that in 2009 an issue with a peanut facility caused a large amount of debris to end up in the pr amt ry lagoon. The Town should determine how much residual material is present and draft a plan to address this issue (see deficiency below). The manual bar screen was in fair condition and screenings are placed into trash receptacles. It was observed that the bar screen is largely ineffective at catching debris due to the spacing of the bars. The Town has a metal working shop and can likely build a better screen. This will reduce the amount of debris entering the primary pump station and the primary lagoon. The influent flowmeter was last calibrated February 2019 by G2 Utilities. The irrigation fields appeared to be in good condition with no evidence of ponding or runoff. The last representative soil analyses were conducted in October 2018. The spray heads appeared to be in good condition, and portions of the spray system were activated and appeared to have good spray patterns and coverage. The chlorination equipment appeared to be in good condition. At the time of the inspection, the facility had plenty of liquid hypochlorite available. NDMR records for 2018-2019 were reviewed. The facility is monitoring the effluent as required but is having the contract lab (Environment 1) analyze far more parameters than required by the permit resulting in additional cost to the Town. During the inspection, the effluent sampling was discussed, and the Town was encouraged to review Attachment A of the current permit to determine exactly which effluent sampling parameters are required. Additionally, the town has not reported values for Total Residual Chlorine (TRC) as required. Reviewing the Towns paperwork, it was observed that the Town is monitoring TRC but it is unclear why these values have not been reported (see deficiency below). Several random months of lab results were compared to NDMR forms with no discrepancies noted. Monitoring wells 8 and 1 were observed and appeared to be in good condition. At the time of the inspection both wells were locked and each well has signage indicating the well number. GW-59 reports for 2018-2019 were reviewed and compared against the lab data. The current permit requires an annual analysis for VOC's every October. The October 2018 GW-59 did not include these results as required, however lab paperwork demonstrates wells were analyzed for VOC's. Please ensure this documentation is included with GW-59's for future sampling events. This office has not received GW-59 reports for the month of February 2019. The facility is not submitting certification forms (GW-59a) and lab results with the GW-59 forms as required by the permit. Additionally, the current permit requires wells to be sampled for Total Phosphorous (TP). The facility is currently not having the wells sampled for this parameter. Please ensure well samples are analyzed for TP. Lastly, Monitoring Well 9 has exceedances of groundwater standards for Chloride and Total Dissolved Solids for every month (except October 2018) where data were reviewed. Please explain why these exceedances may be occurring in Monitoring Well 9 (see deficiencies below). NDAR forms for 2018-2019 were reviewed. 12-month floating totals for spray Fields have not been reported for June 2019. 12-month floating totals —Sum of this month's monthly loading and previous 11 month's monthly loading. Please ensure 12-month floating totals are included on every NDAR submitted. The following permit condition deficiencies were noted during the August 15, 2019 compliance inspection and records review: III.Oaeration and Maintenance Requirements Condition 1, which states that, "The facilities shall be properly maintained and operated at all times." The primary lagoon has a significant amount of solids and debris which reduces capacity. Some of the debris in the primary lagoon could be due to the large spacing in the bar screen. The Town should determine how much residual material is present and draft a plan to address this issue. TV. Monitoring and Reporting Re uirements Condition 4,-which states that, "The Permittee shall monitor effluent from the subject facilities at the frequencies and locations for the parameters specified in Attachment A." The facility is required to sample for Total Residual Chlorine at each spray event. A records review indicates this parameter is not being reported on form NDMR. It was however observed that the Town is taking this measurement. Please ensure TRC is reported on form NDMR as required. Condition I I. -Which states that, "Two copies of monitoring well sampling and analysis results shall be submitted on a Compliance Monitoring Form (GW-59) along with attached copies of laboratory analyses..... and one GW-59a certification form shall be submitted with each set of sampling results." This office has not received GW-59 reports for the month of February 2019. The facility is not submitting certification forms (GW-59a) and lab results with the GW-59 forms as required by the permit. The current permit requires wells to be sampled for Total Phosphorous (TP). The facility is currently not having the wells sampled for this parameter. Monitoring Well 9 has exceedances of groundwater standards for Chloride and Total Dissolved Solids for every month (except October 2018) where data were reviewed. Please explain why these exceedances may be occurring in Monitoring Well 9. Please ensure monitoring well sampling documentation submitted to DWR includes laboratory analyses and the GW-59a Certification Form. Please send February 2019 well sampling documentation (if available) or explain why sampling was not conducted that month. Please ensure well samples are analyzed for TP. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Deficiency regarding your plans or measures to be taken to address the indicated deficiencies and other identified issues, if applicable. Please include in your response all corrective actions already taken and a schedule for completion of any corrective actions not addressed. If you have any questions about this inspection or this letter. please contact Rick Trone at rick.trone_@ncdenr.gov or 919-7914200. Rick Bolich, L.G. Assistant Regional Supervisor Water Quality Regional Operations Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report cc: Central Files RRO Files _om Rance Inspection Report Permit: Wt70004910 Effective: 10/07/16 Expiration: 09/30121 Owner: Town of Woodland SOC: Effective: Expiration: Facility: Town of Woodland WWTF County: Northampton 414 Jameson Ave Region: Raleigh Woodland NC 278970297 Contact Person: Marshall E. Lassiter Title: ORC Phone: 252-585-0411 Directions to Facility: 1-95 N to Rt 158 east towards Conway. Turn right onto Rt 258 south towards Woodland. Turn right on Rt 1557, lagoons and fields are at the end of the road. System Classifications: SI, Primary ORC: Marshall E. Lassiter Certification: 14887 Phone: 252-585-0411 Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 08/15/2019 EntryTime: 10 00AM Primary Inspector: Rick V Trone Secondary Inspector(s): Zachary Thomas Reason for Inspection: Routine Permit Inspection Type: Wastewater Irrigation Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Treatment Record Keeping Treatment Lagoons Treatment Disinfection Wells (see attachment summary) Exit Time: 12.30PM Phone: 919-791-4200 Inspection Type: Compliance Evaluation Treatment Barscreen End Use -Irrigation Page 1 of 6 Permit; W00004910 Owner - Facility -.Town of Woodland Inspection Date: 08115/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On August 15, 2019, Rick Trone, Zach Thomas, and Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation inspection of the wastewater irrigation system for Town of Woodland. The purpose of this Inspection was to ensure compliance with the subject permit. During the Inspection, the cooperation and assistance of Mr. M.E. Lassiter, and Ms. Jessica Griffey was helpful and appreciated. This compliance evaluation inspection consisted of the following: -Review of the permit; -Review of the owner/facility information; -Review of ORC logbooks, calibration documentation, Non -discharge wastewater monitoring reports (NDMR), Non -discharge application reports (NDAR), Compliance Monitoring Fors (GW-59) and; -On-site inspection of treatment components and spray fields The current permit was issued October 7, 2016 and expires on September 30, 2021. Currently, Mr. Lassiter is designated ORC with Christopher Wheeler as backup ORC. Ms. Griffey is currently slated to become ORC soon. Components of the wastewater system appeared to be overall well -maintained and operational. Water In the primary and storage lagoon was free of floating solids and plenty of freeboard was available in the storage lagoon. The primary lagoon has a significant amount of sollds and debris which reduces capacity. Mr. Lassiter explained that In 2009 an Issue with a peanut facility caused a large amount of debris to end up in the primary lagoon. The Town should determine how much residual material Is present and draft a plan to address this issue (see deficiency below). The manual bar screen was In fair condition and screenings are placed Into trash receptacles. It was observed that the bar screen is largely Ineffective at catching debris due to the spacing of the bars. The Town has a metal working shop and can likely build a better screen. This will reduce the amount of debris entering the primary pump station and the primary lagoon. The influent flowmeter was last calibrated February 2019 by G2 Utilities. The irrigation fields appeared to be in good condition with no evidence of ponding or runoff. The last representative soil analyses were conducted in October 2018. The spray heads appeared to be in good condition, and portions of the spray system were activated and appeared to have good spray patterns and coverage. The chlorination equipment appeared to be in good condition. At the time of the inspection, the facility had plenty of liquid hypochlorite available. NDMR records for 2018-2019 were reviewed. The facility is monitoring the effluent as required but is having the contract lab (Environment 1) analyze far more parameters than required by the permit resulting in additional cost to the Town. During the inspection, the effluent sampling was discussed, and the Town was encouraged to review Attachment A of the current permit to determine exactly which effluent sampling parameters are required. Additionally, the town has not reported values for Total Residual Chlorine (TRC) as required. Reviewing the Towns paperwork, it was observed that the Town is monitoring TRC but It Is unclear why these values have not been reported (see deficiency below). Several random months of lab results were compared to NDMR forms with no discrepancies noted. Monitoring wells 8 and 1 were observed and appeared to be in good condition. Al the time of the inspection both wells were locked and each well has signage indicating the well number. GW-59 reports for 2018-2019 were reviewed and compared against the lab data. The current permit requires an annual analysis for VOC's every October. The October 2018 GW-59 did not include these results as required, however lab paperwork demonstrates wells were analyzed for VOC's. Please ensure this documentation Is included with GW-59's for future sampling events. This office has not received GW-59 reports for the month of February 2019. The facility Is not submitting certification forms (GW-59a) and lab results with the GW-59 forms as required by the permit. Additionally, the current permit requires wells to be sampled for Total Phosphorous (TP). The facility is currently not having the wells sampled for this parameter, Please ensure well samples are analyzed for TP. Lastly, Monitoring Well 9 has exceedances of groundwater standards for Chloride and Total Dissolved Solids for every month (except October 2018) where data were reviewed. Please explain why these exceedances may be occurring in Monitoring Well 9 (see deficiencies below). NDAR forms for 2018-2019 were reviewed. 12-month floating totals for spray fields have not been reported for June 2019. 12-month floating totals=Sum of this month's monthly loading and previous 11 month's monthly loading. Please ensure Page 2 of 6 Permit: W00004910 Owner - Facility:Town of woodland Inspection auto: 081mo19 Inspection TYPO: Compliance Evaluation Reason tar Vlslt: Routine 12-month floating totals are included on every NDAR submitted. The following permit condition deficiencies were noted during the August 15, 2019 compliance inspection and records review: Ill. Operation and Maintenance Requirements Condition 1, which states that, "The facilities shall be properly maintained and operated at all times." The primary lagoon has a significant amount of solids and debris which reduces capacity. Some of the debris in the primary lagoon could be due to the large spacing in the bar screen. The Town should determine how much residual material is present and draft a plan to address this issue. IV. Monitoring and Reporting Requirements Condition 4, which states that, "The Permittee shall monitor effluent from the subject facilities at the frequencies and locations for the parameters specified in Attachment A." The facility is required to sample for Total Residual Chlorine at each spray event. A records review indicates this parameter is not being reported on form NDMR. It was however observed that the Town is taking this measurement. Please ensure TRC is reported on form NDMR as required. Condition 11, which states that, "Two copies of monitoring well sampling and analysis results shall be submitted an a Compliance Monitoring Form (GW-59) along with attached copies of laboratory analyses.....and one GW-59a certification form shall be submitted with each set of sampling results." This office has not received OW-59 reports for the month of February 2019, The facility is not submitting certification forms (GW-59a) and lab results with the GW-59 forms as required by the permit. The current permit requires wells to be sampled for Total Phosphorous (TP). The facility is currently not having the wells sampled for this parameter. Monitoring Well 9 has exceedances of groundwater standards for Chloride and Total Dissolved Solids for every month (except October 2018) where data were reviewed. Please explain why these exceedances may be occurring in Monitoring Well 9. Please ensure monitoring well sampling documentation submitted to DWR Includes laboratory analyses and the GW-59a Certification Form. Please send February 2019 well sampling documentation (if available) or explain why sampling was not conducted that month. Please ensure well samples are analyzed for TP. Page 3 of 6 Permit: W00004910 Owner -Facility: Town of Woodland Inspection Date: 0811512019 Inspection Type: Compliance Evaluation Reason for Visit: Routine TV09 Yes No NA NE S ngle Family Drip ❑ Activated Sludge Spray, HR 0 Reuse (Quality) ❑ Activated Sludge Drip, LR ❑ Infiltration System ❑ Recycle/Reuse ❑ Lagoon Spray, LR 0 Single Family Spray, LR 0 Activated Sludge Spray, LR Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? 0 0 1:111. Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑ Comment: The bar screen is not listed in the permit. Bar screen is located at the main lift station. Treatment Barscreen Yes No NA NE Is it free of excessive debris? ■ ❑ ❑ ❑ Is disposal of screenings in compliance? M000 Are the bars spaced properly? Is the unit in good condition? ON00 Comment: It was observed that the bar screen is larCleIV ineffective at Catching debris due to the spacing of the bars. The Town has a metal workinci shop and can likely build a better screen. This will reduce the amount of debris entering the primary pump station and the orimary lagoon Treatment Disinfection Yes No NA NE Is the system working? ■ ❑ 0 ❑ Do the fecal coliform results indicate proper disinfection? 0El❑ ❑ Is there adequate detention time (> 30 minutes)? M Is the system properly maintained? M If gas, does the cylinder storage appear safe? Is the fan In the chlorine feed room and storage area operable? Is the chlorinator accessible? 0❑ If tablets, are tablets present? a Are the tablets the proper size and type? Is contact chamber free of sludge, solids, and growth? 0 If UV, are extra -UV bulbs available? It UV, is the UV intensity adequate? Page 4 of 6 Permit: WO0o04910 owner • Facility: Town of Woodland Inspection Date: 08115/2019 Inspection Type: Compl ance Evaluation Reason for Visit: Routine # Is it a dual feed system? Does the Stationary Source have more than 2500 Ibs 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- ❑ ❑ • o If yes, then when was the RMP last updated? Comment: Record Keeping Is a copy of current permit available? 1'tA--N€ Are monitoring reports present, NDMR? ■ ❑ ❑ ❑ NDAR? • ❑ ❑ ❑ Are now rates less than of permitted flow? ■ ❑ ❑ ❑ Are (low rates less than of permitted flow? • ❑ Cl ❑ Are application rates adhered to? ■ ❑ ❑ ❑ Is GW monitoring being conducted, if required (GW-59s submitted)? ■ O ❑ ❑ Are all samples analyzed for all required parameters? ■ ❑ ❑ ❑ Are there any 2L GW quality violations? ❑ ■ ❑ ❑ Is GW-59A certification form completed for facility? ■ O ❑ ❑ Is effluent sampled for same parameters as GW7 ❑ ■ ❑ ❑ Do effluent concentrations exceed GW standards? ■ ❑ ❑ ❑ Are annual soil reports available? ❑ ❑ ■ ❑ # Are PAN records required? ■ ❑ ❑ ❑ # Did last soil report indicate a need for lime? a ❑ • ❑ If so, has It been applied? ■ ❑ ❑ Are operational togs present? ❑■❑❑ Are lab sheets available for review? ■ ❑ ❑ ❑ Do lab sheets support data reported on NDMR? ■ ❑ ❑ ❑ Do lab sheets support data reported on GW-59s7 ■ ❑ ❑ ❑ Are Operational and Maintenance records present? ■ ❑ ❑ ❑ Were Operational and Maintenance retards complete? ■❑ ❑❑ Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑ Is a copy of the SOC readily available? ■ ❑ ❑ ❑ No treatment units bypassed since last inspeclion7 ❑❑■❑ Comment: See Summary, 0000 End Use-Irrl atlon Are buffers adequate? Yss No NA NE Is the cover crap type specified in permit? ❑ ❑ ❑ ■ ❑ ❑ ❑ Page 5 of 6 Permit: WQ0004910 Owner • Facility: Town of Woodland Inspeetlan Date: 0811512019 Inspection Type -Compliance Evaluation Reason for Visit: Routine Is the crop cover acceptable? 0❑ 0 ❑ Is the site condition adequate? N❑ ❑ Is the site free of runoff ! ponding? Is the acreage specified in the permit being utilized? Is the application equipment present? Is the application equipment operational? Is the disposal field free of limiting slopes? 11 Is access restricted and/or signs posted during active site use? Are any supply wells within the CB? ■ Are any supply wells within 250' of the CB? 0 How close is the closest water supply well? 0 0 0 Is municipal water available in the area? 0 0 11 . At Info only: floes the permit call for monitoring wells? M Are GW monitoring wells located properly w/ respect to RB and CB? Are GW monitoring wells properly constructed, including screened interval? 0 0 0 Are monitoring wells damaged? 0 0 ■ Comment: Page 6 of 6