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HomeMy WebLinkAboutNC0020931_NOV and Intent to Assess_20190823ROY COOPER {;overrirr MICHAEL S. REOAN Serrezwry LI:NDA CULPEPPER � Y4Ytnr Certified Mail # 7011 1570 0001 8546 4303 Return Receipt Requested Russell Hunter, IV Town of Boonville PO Box 326 Boonville, NC 27011-0326 NORTH CAROLINA Erry ronmentaf Quality August 23, 2019 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-OV-0003 Permit No. NCO020931 Boonville WWTP Yadkin County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Boonville WWTP on August 15, 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. NC0020931. 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 Winston-Salem Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Permit Current permit not available on site. Effluent Sampling Effluent sampler aliquot was not as programmed (442% more than programmed). Laboratory Field lab certification not on site. Operations & Maintenance Many components dilapidated and in poor condition. Facility dependability is questionable. Operations & Maintenance None of the currently designated backup operators work at the facility. No backup ORC is assigned. Secondary Clarifier Scum skimmer on operational rectangular treatment train's clarifier ineffective. Laboratory Several data points on the DMRs reviewed during the inspection (May - July 2018) were erroneous, and also, several other data points on the DMRs reviewed did not have matching data points on the lab bench sheets, or anywhere else, as source data. North Carc, Departro�-rtofErtvmror v. � -t_. I ❑Msk)rtofWater Resortrces W:rtstort-& =µ R—e ona Off, i 4M a - oad. Swte 300 1 V:' nstart�- _ North U c-_ ^a 27105 Inspection Area Description of Violation Operations & Maintenance The middle rectangular treatment train floated about 2 years ago and remains inoperable. Secondary Clarifier Weir on operational rectangular treatment train's clarifier not level. A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) 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. If you wish to provide additional information regarding the noted violations, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business day after receipt of this Notice. A review of your response will be considered along with any additional information provided. You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Where possible, remedial actions should have already been taken to correct these problems and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you should have any questions, please do not hesitate to contact Ron Boone with the Water Quality Regional Operations Section in the Winston-Salem Regional Office at 336-776-9800. Sincerely, Doc uSigned<by: -,'[349E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ ATTACHMENTS EPA Water Compliance Inspection Report cc: WQS Winston-Salem Regional Office - Enforcement File North 03r€;„r.sDepartmentofEnwrQnmentslQus t, I Dv..s:ortofWater Resources W:nstonSaSem Reg oraadOffice 1 450 West Fares V Road, Swte3.00 1 W.RstonSeern, North Caro i rra 27105 H .6 336-77£3-?WO 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 15 I 3 I NC0020931 111 12 I 19/08/15 I17 18 L d 19 L s j 201 211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---------------------- Reserved ------------------- 671 70I,—71 J72 n73I——!74 751 I I I I 80 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) 09:OOAM 19/08/15 19/01/01 Boonville WWTP 110 Carolina Ave Exit Time/Date Permit Expiration Date Boonville NC 27011 12:OOPM 19/08/15 23/12/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Jeffrey Eugene Jones/ORC/252-639-7544/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Gardner,PO Box 326 Boonville NC 270110326//336-367-7941/3363674205 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 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 Ron Boone DocuSigned by: WSRO WQ//336-776-9690/ *%,*& 8/23/2019 Signature of Management Q A Reviewer uSigned by: Agency/Office/Phone and Fax Numbers Date -T Stiidu- 8/23/2019 E�-5'1349E225CWEA... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO020931 111 121 19/08/15 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The Boonville plant is certified to run pH, DO, and temperature with NC field lab certificate number 5665. However, there were several issues as follows: 1. The operator, Jeff Jones, did not have the 2019 certificate at the plant. Mr. Boone called the lab cert unit after the inspection to verify their 2019 certification. Mr. Jones must find his certificate or call the lab cert unit to request a replacement. In the future Mr. Jones must take better care to receive and properly care for their new certificate each year. Mr. Boone examined the 2015 and 2018 certifcates and accompanying letters and parameter lists. Both letters were dated in May of each respective year, but when Mr. Boone spoke with lab cert personnel, they informed him that new certificates are mailed in December of each year, so, it is unknown, at this point, why Boonville's letters were dated May. *In your response letter please provide an updated status of your field laboratory certification. 2. In comparing lab bench sheets, which also serve to record other items such as date/time, operator name, flow meter readings, etc, with the final version of the DMRs, several DMR data points were either erroneous, to varying extents, or matching bench sheet data did not exist for some DMR data points. Mr. Boone expressed concern over the errors but also told the operator that the missing bench sheet data was of even more concern, because it is potentially indicative of falsified data. Mr. Jones explained the data gathering process used at the plant as follows: Operators take meters from the lab/plant building to take the needed readings and return to the lab/plant building and write them on a dry erase board that is just inside the door. From there the data is supposed to be transferred to the bench sheets, although it is unclear who is responsible for the transfer and within what time frame the data should be transferred. It is also unclear how the data is recorded while the operator is in the field before it is transferred to the dry erase board. From the bench sheet the data is transferred to a draft DMR and then finally the data is transferred to eDMR for finalization. Mr. Boone informed Mr. Jones that the process needs to be improved and streamlined to prevent further errors and missing data points in the future. Mr. Jones could not explain the missing data points but acknowledged the seriousness of the issue. *In your response letter please answer the following questions in detail: a. Please explain how operators record data collected in the field, before it is placed on the dry erase board. b. Who is responsible for transferring the data from the dry erase board to the benchsheets and within what time frame are they required to do so? c. Is it verified that dry erase board data has been transferred to the bench sheets before it is destroyed? d. Please explain in detail your plan to improve the data collection/recordation process to guarantee future violations of this type are averted completely. 3. Data exists on the bench sheets that is not reported on DMRs. Although the data is above and beyond what is required by the permit, it must still be recorded/reported on the DMRs. Mr. Jones must begin reporting all acquired data. *In your response letter please explain in detail your plan to improve the data collection/recordation process to guarantee the future reporting of all data collected by plant staff. 4. The tubing on the influent sampler should be replaced. The influent sampler was not tested during the inspection but the effluent sampler was and did not sample according to its program; it's programmed to pull 120 milliliters every 40 pulses but it pulled 530 milliliters. Mr. Boone asked Mr. Page# 2 Permit: NCO020931 Inspection Date: 08/15/2019 Owner - Facility: Boonville WWTP Inspection Type: Compliance Evaluation Jones to investigate and correct this discrepancy. Given the significant discrepancy on the effluent sampler, the influent sampler should be verified as well. *In your response letter please answer the following questions in detail: a. Please tell us when the influent sampler's tubing will be replaced. b. Please tell us the influent sampler's flow regime and whether it is sampling according to its program. c. If it is not sampling according to its program, please tell us when this will be corrected. 5. The effluent sampler was tested and did not sample according to its program; it's programmed to pull 120 milliliters every 40 pulses but it pulled 530 milliliters for the first aliquot when the sampling regime was initiated. Mr. Boone asked Mr. Jones to investigate and correct this discrepancy. Given the significant discrepancy on the effluent sampler, the influent sampler should be verified as well. *In your response letter please answer the following questions in detail: a. Please tell us when the effluent sampler will be repaired and reprogrammed to sample properly. b. Please tell us why the effluent sampler wasn't sampling properly. 6. The plant description lists a comminutor but there isn't one installed. The plant description should be updated to correct this mistake. *No action is required until the next permit renewal. Please correct the plant description at that time. 7. None of the currently assigned backup operators currently work at the plant. Mr. Jones stated that Mr. Steve Hutchins is his backup operator but he is not so designated in DWR's database. Mr. Jones must properly designate the backup ORC(s) by submitting the necessary paperwork. *In your response letter please answer the following questions in detail: a. Please tell us why no appropriately certified backup operators are assigned. b. Please tell us your timeline to have appropriately certified operators properly designated as backup operators. 8. The plant has temporary mobile frac tanks on site for the purpose of diverting excess flow as needed. A temporary diesel pump transfers excess water to the frac tanks and comes on automatically using a float sensor when the level in the influent splitter box gets too high. *No action is required at this time. 9. There is no influent meter. Both the influent and effluent samplers are connected to the effluent meter for flow proportional sampling. So, influent flow proportional composite samples are paced off the effluent flow. *No action is required at this time. 10. The bar screenings are placed on the old drying beds, the underdrains of which are still connected to the plant's influent line. The screenings are then hauled to landfill. Wet sludge is applied to one of five Page# Permit: NCO020931 Inspection Date: 08/15/2019 Owner - Facility: Boonville WWTP Inspection Type: Compliance Evaluation drying beds and dried sludge is stockpiled in the same old drying beds that bar screenings are placed in and also landfilled. *No action is required at this time. 11. The mixed liquor in both operational aeration basins looked very good and imparted a pleasant earthy odor. Aeration looked good with no dead spots, short circuiting, etc. Mr. Jones stated they keep the DO at about 4 mg/I with no problems. Diffused aeration appeared very effective. DO was not tested during the inspection. *No action is required at this time. 12. The sludge blanket in the operational rectangular unit's clarifier was about 2'. The overflow was very clear with very little pin floc. However, the weir on this unit is slightly off level and more wastewater flows over the eastern side of the weir. Although it did not appear to be causing short circuiting, which may have been because of a relatively low flow rate at the time, the weir should be level to best guarantee proper operation and treatment. Also, the skimmer on this unit is ineffective and should be repaired/replaced. *In your response letter please answer the following questions in detail: a. Please indicate whether short circuiting ever occurs in this clarifier. b. Please indicate what the town's plans are to level the weir. c. Please indicate what the town's plans are to repair this clarifier's scum skimmer. 13. The UV disinfection unit appeared well maintained and effective. The effluent was very clear. *In your response letter please tell us what backup disinfection system the plant employs. 14. This plant consists of three individual package trains; one circular (100K GPD), and two rectangular (50K GPD each). One of the rectangular units floated approximately 2 years ago when it was emptied to facilitate maintenance and resurfacing. Unfortunately, the unit has not been reset and placed back in service yet, in part due to difficulties the town has experienced with the first contractor that was hired to do the work. A new contractor has now been hired. *In your response letter please answer, in detail, the following questions: a. Why the tank has NOT been reset and placed back in service. b. Where the town is in the process of getting the tank reset and placed back in service. c. What needs to be done to make this happen as well as the town's plan to make it happen as quickly as possible. 15. Several components are quite dilapidated, are inefficient, or don't even exist; such as, a. The Parshall flume (concrete cracked and spalling); b. The floated treatment train (no explanation required); c. Grit and/or grease removal (non-existent); d. Permanent flow equalization (non-existent); e. Haphazardly constructed guard rails, as well as many other plant components (no explanation required); Page# Permit: NC0020931 Inspection Date: 08/15/2019 Owner - Facility: Boonville WWTP Inspection Type: Compliance Evaluation f. Two treatment units still need resurfacing and maintenance, (no explanation required); g. Walk ways on the circular treatment train are made from wood that looks very old and weak and therefore very unsafe (no explanation required); Facility dependability is questionable. The town needs to begin investing significant time and capital in the plant in order to maintain what's there in safe and efficient working condition and/or to replace what's currently there. This is the only way to guarantee future compliance with the town's NPDES permit. 16. Mr. Jones indicated that the generator runs automatically under load for approximately 15 minutes every Wednesday morning. In your response letter, please answer the following questions: a. Please indicate whether this test is initiated by interrupting the primary power source, or by simply flipping the switch. b. Please indicate how the operators monitor the generator's fuel level. c. Please tell us whether there currently exists an emergency fuel supply agreement/contract with a dependable fuel vendor. Page# Permit: NCO020931 Owner - Facility: Boonville WWTP Inspection Date: 08/15/2019 Inspection Type: Compliance Evaluation 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 ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ 0 ❑ ❑ # 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? 0 ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑0 ❑ ❑ 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 0 ❑ ❑ ❑ representative)? Comment: Please refer to the inspection summary section. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: None Page# 6 Permit: NCO020931 Owner - Facility: Boonville WWTP Inspection Date: 08/15/2019 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 ❑ ❑ ❑ application? Is the facility as described in the permit? ❑ 0 ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ 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 plant description lists a comminuter but there isn't one installed. The plant description should be updated to correct this mistake. 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? 0 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ 0 ❑ ❑ 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? ❑ 0 ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ 0 ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Please refer to the inspection summary section. Equalization Basins Yes No NA NE Is the basin aerated? ❑ 0 ❑ ❑ Page# 7 Permit: NC0020931 Owner - Facility: Inspection Date: 08/15/2019 Inspection Type: Boonville WWTP Compliance Evaluation Equalization Basins Yes No NA NE Is the basin free of bypass lines or structures to the natural environment? ❑ ❑ ❑ Is the basin free of excessive grease? ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ❑ # Is basin size/volume adequate? ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Flow Measurement - Influent 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? ❑ ❑ ❑ Comment: There is no influent meter. Both the influent and effluent samplers are connected to the effluent meter for flow proportional sampling. 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 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Screenings are placed on old drying beds, the underdrains of which are still connected to the plant's influent line. The screenings are then hauled to landfill. 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 ❑ Are the diffusers operational? ❑ ❑ ❑ Page# 8 Permit: NCO020931 Owner - Facility: Boonville WWTP Inspection Date: 08/15/2019 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Mixed liquor looked and smelled very good. Aeration looked great. No dead spots, short circuiting, etc. Mr. Jones stated they keep the DO at about 4 mg/I with no problems. Did not test it during the inspection. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ 0 ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ❑ 0 ❑ ❑ Is scum removal adequate? ❑ 0 ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0 ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ ❑ Comment: Please indicate what spare parts/pumps are kept on hand in your response letter. Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ Is UV intensity adequate? 0 ❑ ❑ ❑ Is transmittance at or above designed level? ❑ ❑ ❑ Is there a backup system on site? ❑ ❑ ❑ Page# 9 Permit: NCO020931 Inspection Date: 08/15/2019 Disinfection - UV Is effluent clear and free of solids? Owner - Facility: Boonville WWTP Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ Comment: Please indicate in your response letter the transmittance level and what the backup disinfection system is. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? 0 ❑ ❑ ❑ Comment: Meter last calibrated in November 2018. 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? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: None 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: Please refer to the inspection summary section. Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? ❑ ❑ ❑ 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? ❑ ❑ ❑ Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Page# 10