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Home My WebLink AboutWQ0028552_NOV-2019-PC-0658 Followup Inspection_20200121ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality January 2I, 2020 CERTIFIED MAIL 7017 2680 0000 2235 8779 RETURN RECEIPT REQUESTED Mr. Michael Myers Old North State Water Company, LLC 1620 Chalk Road Wake Forest, NC 27587 Subject: CONTINUING NOTICE OF VIOLATION NOV-2019-PC-0658 Follow-up Inspection Briar Chapel Development Reclaimed Water Generation, Conjunctive Reclaimed Water Utilization, Non -Conjunctive Reclaimed Water Utilization, and Wastewater Irrigation System Permit Number WQ0028552 Chatham County Mr. Myers, On January 10, 2020, Rick Trone and Scott Vinson of the Raleigh Regional Office, Division of Water Resources (DWR) conducted follow-up inspection of the non -conjunctive and conjunctive wastewater treatment and reclaimed water utilization system located at the Briar Chapel Development. The purpose of this inspection was to reinspect areas of concern from a previous inspection in September 2019. During the inspection, the cooperation of Lee Bowman, William Lamm, Chuck Donnell, and Kenny Harris was helpful and appreciated. Also present was John Sharp, the subcontractor for the irrigation system from Quality Landscaping. This compliance evaluation inspection consisted of the following: Non -discharge wastewater monitoring reports (NDMR), Non -discharge application reports (NDAR) and; On -site inspection of treatment components; Investigation of system operation to help determine the cause for numerous complaints that the DWR has received for the wastewater treatment plant and reclaimed water distribution system for Briar Chapel. �� North Carolina Department of Environmental Quality I Division of Water Resources D ,._ Raleigh Regional Office 1 3800 Barrett Drive I Raleigh. North Carolina 27609 °i�� 919.79IA200 Mr. Michael Myers, Old North State Water Company, LLC. NOV-2019-PC-0658 January 21, 2020 The odor control system at the headworks of the package plant appeared to be operational. The manual bar screens require frequent spray downs with hoses and frequent cleaning to keep them clear. It was explained that large amounts of food waste entering the system is one major contributor to odor at the plant. The screenings fall below into a large dumpster. The headworks of the plant are covered but the double doors on the building have a large gap at the top when the doors are closed. A strong odor was noticed coming from this area. DWR recommends modifying the door closure mechanism to reduce or eliminate this gap. This change may help reduce the amount of odor residents are concerned about. Water within the package plant was of normal color for domestic wastewater, however, excess foam was still present like what was observed on the September visit. A skimmer pipe in the clarifier was broken. It could not be determined if the ultraviolet lights were operational on one bank due to the display not working. Staff mentioned that the bank with the inoperative display was working, but half of the lights in that bank were inoperative. The composite effluent sampler thermometer indicated the sampler was just above freezing and some ice was observed. This should be corrected to prevent the sample from freezing. As in the previous inspection, the turbidimeter was flashing an error message consisting of an exclamation point flashing on the screen. A review of the instrument's user manual confirms this is indeed an error message and should be resolved. Following the previous inspection, Old North State Water Company indicated a technician from Delta Systems Environmental inspected this meter and reported it was functioning correctly at that time, however, an issue clearly still exists. A review of NDMR records since the September inspection finds that the issues noted have been corrected, the facility is using updated forms and is now reporting all required parameters for effluent sampling. Since the previous inspection, the facility has submitted NDMR's for PP1002, however the forms are blank. A review of NDAR forms indicate reclaimed water was distributed for conjunctive utilization. Water distributed for conjunctive utilization should also be reported on the NDMR for PPI002. The facility maintains numerous irrigation areas within the development. The areas observed during the inspection appeared to have an acceptable cover crop with no evidence of ponding or runoff. The following permit condition violations were noted during the January 10, 2020 follow-up inspection and records review: Ill. OPERATION AND MAINTAINANCE REQUIREMENTS Condition 1, which states that, "the reclaimed water generation and utilization facilities shall be properly maintained and operated at all times..." Numerous issues were observed in and around the package plant (see above). Please explain the reason for the issues observed during the inspection in your response to items 1-6 in the "REQUESTED RESPONSE" section of this Notice. IV. MONITORING AND REPORTING REQUIREMENTS Condition 4, which states that, "the Permittee shall monitor the reclaimed water from the generating facility at the frequencies and locations for the parameters specified...." Since the previous inspection in September 2019, the facility has not submitted data on form NDMR for PPI002 (Reclaimed Water Distributed for Conjunctive Utilization Phases I-E, 1-F, and 1-G). A review of NDAR forms indicates Mr. Michael Myers, Old North State Water Company, LLC. NOV-2019-PC-0658 January 21, 2020 conjunctive utilization did occur. Water distributed for conjunctive utilization should also be reported on the NDMR for PP1002. If no flow occurred, indicate this on the form for PPI002. REOUESTED RESPONSE: 1. Please explain the presence of excessive foam that is still present at the wastewater treatment plant. 2. Please indicate when the skimmer pipe in the clarifier will be repaired. 3. Please ensure that the turbidity meter is operating properly and provide this office with proof the meter is functioning. The error message observed during the September 2019 inspection was still present during the follow-up inspection indicating there is an issue with the meter. 4. Please ensure the facility reports conjunctive reclaimed water distribution on form NDMR for PP1002. 5. Please explain why the ultraviolet light system currently has one half of one bank of lights inoperative. Please also explain when the display for that bank and the bulbs will be replaced or repaired. 6. Please describe efforts that Old North State Water Company has taken to address resident complaints about the wastewater treatment plant and the reclaimed water distribution system. This office requests that you respond to this letter in writing within 30 days of receipt. Your response should be sent to this office at the letterhead address. Your response should address the following items as noted above. Please include in your response all corrective actions already taken and a schedule for completion of any corrective actions not addressed. Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to the Director of the Division of Water Resources who may issue a civil penalty assessment of not more that twenty-five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance with the terms, conditions, or requirements of a permit under authority of G.S. 143-215.6A. If you have any questions about this inspection or this letter, please contact Rick Trone at rick.trone[a)ncdenr.gov or 919-7914200. Sincerely, Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Mr. Michael Myers, Old North State Water Company, LLC. NOV-2019-PC-0658 January 21, 2020 Attachments: EPA Water Compliance Inspection Report cc: Central Files RRO Files Laserfiche Compliance Inspection Report Permit: W00028552 Effective: 04107/16 Expiration: 03/31/21 Owner: Old North State Water Company LLC SOC: Effective: Expiration: Facility: Briar Chapel Development County: Chatham 540 Boulder Point Dr Region: Raleigh Chapel H II NC 27516 Contact Person: Tracy D Miller Title: Envirolink Area Manager Phone: 919-437-6001 Directions to Facility: System Classifications: SI, WW3., Primary ORC: Certification: Phone! Secondary ORC(s): On -Site Representative(s): Related Permits: W00029867 Old North State Water Company LLC - Boar Chapel Subdivision A & B W00032565 Old North State Water Company LLC - Briar Chapel - Pokeberry Creek Utility Crossing Inspection Date: 0111012020 EntryTime: 10 00AM Exit Time: 11.30AM Primary Inspector: Rick V Trone Phone: 919-7914200 Secondary Inspector(s)- Rick Bol:ch Zachary Thomas Reason for Inspection: Follow-up Permit Inspection Type: Rectaimed Water Facility Status: ❑ Compliart Not Compliant Question Areas: Inspection Type: Compliance Evaluation Miscellaneous Questions 0 Treatment Record Keeping M End Use -Irrigation Treatment Clarifiers M Treatment Disinfection (See attachment summary) Treatment Barscreen Treatment Influent Pump Station Storage Page I of 7 Permit: W00028552 Owner - Facility: Old North State Water Company LLC Inspection pate: 01/10/2020 Inspection Typo: Compliance Evaluation Reason for Visit. Follow-up Inspection Summary: On January 10, 2020, Rick Trone and Scott Vinson of the Raleigh Regional Office, Division of Water Resources (DWR) conducted follow-up Inspection of the non -conjunctive and conjunctive wastewater treatment and reclaimed water utilization system located at the Briar Chapel Development. The purpose of this inspection was to reinspect areas of concern from a previous inspection in September 2019. During the inspection, the cooperation of Lee Bowman, William Lamm, Chuck Donnell, and Kenny Harris was helpful and appreciated. Also present was John Sharp, the subcontractor for the irrigation system from Quality Landscaping. This compliance evaluation inspection consisted of the following: -Non-discharge wastewater monitoring reports (NDMR), Non -discharge application reports (NDAR) and; "On -site inspection of treatment components and; -investigation of system operation to help determine the cause for numerous complaints that the DWR has received for the wastewater treatment plant and reclaimed water distribution system for Briar Chapel. The odor control system at the headworks of the package plant appeared to be operational. The manual bar screens require frequent spray downs with hoses and frequent cleaning to keep them clear. It was explained that large amounts of food waste entering the system is one major contributor to odor at the plant. The screenings fall below into a large dumpster. The headworks of the plant are covered but the double doors on the building have a large gap at the top when the doors are closed. A strong odor was noticed coming from this area. DWR recommends modifying the door closure mechanism to reduce or eliminate this gap. This change should reduce the amount of odor residents are concerned about. Water within the package plant was of normal color for domestic wastewater, however, excess foam was still present like what was observed on the September visit. A skimmer pipe in the clarifier was broken. It could not be determined if the ultraviolet lights were operational on one bank due to the display not working. Staff mentioned that the bank with the inoperative display was working, but half of the lights in that bank were inoperative. The composite effluent sampler thermometer indicated the sampler was just above freezing and some ice was observed. This should be corrected to prevent the sample from freezing. As in the previous inspection, the turbidimeter was flashing an error message consisting of an exclamation point flashing on the screen. A review of the instrument's user manual confirms this is indeed an error message and should be resolved. Following the previous inspection, Old North State Water Company indicated a technician from Delta Systems Environmental inspected this meter and reported it was functioning correctly at that time, however, an issue clearly still exists. A review of NDMR records since the September inspection finds that the issues noted have been corrected, the facility is using updated forms and is now reporting all required parameters for effluent sampling. Since the previous inspection, the facility has submitted NDMR's for PPI002, however the forms are blank. A review of NDAR forms indicate reclaimed water was distributed for conjunctive utilization. Water distributed for conjunctive utilization should also be reported on the NDMR for PPI002. The facility maintains numerous irrigation areas within the development. The areas observed during the inspection appeared to have an acceptable cover crop with no evidence of ponding or runoff. The following permit condition violations were noted during the January 10, 2020 follow-up inspection and records review; Ill. OPERATION AND MAINTAINANCE REQUIREMENTS Condition 1, which states that, "the reclaimed water generation and utilization facilities shall be properly maintained and operated at all times..." Numerous issues were observed in and around the package plant (see above). Please explain the reason for the issues observed during the inspection in your response to items 1-6 in the "REQUESTED RESPONSE" section of this Notice. IV. MONITORING AND REPORTING REQUIREMENTS Condition 4, which states that, `the Permittee shall monitor the reclaimed water from the generating facility at the Page 2 of 7 permit: W00028552 Owner - Facility: Old North State Water Company LLC Inspection Date: 01/1012020 Inspection Type : Compliance Evaluation Reason for visit: Follow-up frequencies and locations for the parameters specified...." Since the previous inspection in September 2019, the facility has not submitted data on form NDMR for PPI002 (Reclaimed Water Distributed for Conjunctive Utilization Phases 1-E, 1-F, and 1-G). A review of NDAR forms indicates conjunctive utilization did occur. Water distributed for conjunctive utilization should also be reported on the NDMR for PP1002. If no flow occurred, indicate this on the form for PPI002. REQUESTED RESPONSE: 1. Please explain the presence of excessive foam that is still present at the wastewater treatment plant. 2. Please indicate when the skimmer pipe in the clarifier will be repaired. 3. Please ensure that the turbidity meter is operating properly and provide this office with proof the meter is functioning. The error message observed during the September 2019 inspection was still present during the follow-up inspection indicating there is an issue with the meter. 4. Please ensure the facility reports conjunctive reclaimed water distribution on form NDMR for PPI002. 5. Please explain why the ultraviolet light system currently has one half of one bank of lights inoperative. Please also explain when the display for that bank and the bulbs will be replaced or repaired. 6. Please describe efforts that Old North State Water Company has taken to address resident complaints about the wastewater treatment plant and the reclaimed water distribution system. Page 3 of 7 Permit: W00028552 Owner - Facility: Old North State Water Company LLC Inspection Onto: 01/1012020 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up TvVe Yes No NA NE Reuse (Quality) ❑ Infiltration System ❑ Lagoon Spray, LR ❑ Single Family Spray, LR ❑ Activated Sludge Spray, LR ❑ Activated Sludge Spray, HR ❑ Activated Sludge Drip, LR ❑ Recycle/Reuse ❑ Single Family Drip ❑ Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑ Do all treatment units appear to be operational? (if no, note below.) ❑ ❑ ❑ Comment: See summary. Treatment Influent Pump Station Yes No NA NE Is the pump station free of bypass lines or structures? M ❑ ❑ ❑ Is the general housekeeping acceptable? M ❑ ❑ ❑ Are all pumps present? M ❑ ❑ ❑ Are all pumps operable? ❑ ❑ M ❑ Are floats/controls operable? ❑ ❑ ❑ 0 Are audio and visual alarms available? ❑ ❑ ❑ 0 Are audio and visual alarms operational? ❑ ❑ ❑ M # Are SCADA/Telemetry alarms required? ❑ ❑ M ❑ Are SCADAfTelemetry available? ❑ ❑ N ❑ Are SCADAITelemetry operational? ❑ ❑ 0 ❑ Comment: Treatment Barscreen Yes No NA N Is it free of excessive debris? M ❑ ❑ ❑ Is disposal of screenings in compliance? N ❑ ❑ ❑ Are the bars spaced properly? M ❑ ❑ ❑ Is the unit In good condition? M ❑ ❑ ❑ Comment: Treatment Clarifiers Yes No NA NE Are the weirs level? M ❑ ❑ ❑ Page 4 of 7 Permit: W00028552 Owner - Facility: Old North State Water Company LLG Inspection Gate: 01/10/2020 Inspection Type • Compliance Evaluation Reason for Visit: Follow. Up Are the weirs free of solids and algae? 0 ❑ 0 ❑ Is the scum removal system operational? ❑ M o Is the scum removal system accessible? 0 t] ❑ Is the sludge blanket at an acceptable level? 0 111:11:1 Is the effluent from the clarifier free of excessive solids? 0 Comment: Skimmer pipe broken. Treatment Disinfection Yes No NA NE Is the system working? Do the fecal coliform results indicate proper disinfection? Is there adequate detention time (-30 minutes)? Is the system properly maintained? 0■ 00 If gas, does the cylinder storage appear safe? 0 0N Is the fan In the chlorine feed room and storage area operable? ❑ E Is the chlorinator accessible? N If tablets, are tablets present? Are the tablets the proper size and type? Is contact chamber free of sludge, solids, and growth? 0 11 ❑ If UV, are extra UV bulbs available? 0 0 on If UV, is the UV Intensity adequate? # Is it a dual feed system? E 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-_ _) If yes, then when was the RMP last updated? Comment: Display for UV light system inoperable. One half of one bank (8 lights) inoperable. Record Keeping Yes No NA NE Is a copy of current permit available? 0 [] ❑ ❑ Are monitoring reports present: NDMR? 0 11 ❑ ❑ NDAR? N 111:10 Are flow rates less than of permitted flow? 00 Are flow rates less than of permitted flow? 0 0 00 Are application rates adhered to? 0 11 No Is GW monitoring being conducted, if required (GW-59s submitted)? 0 0 ■ o Are all samples analyzed for all required parameters? Are there any 2L GW quality Aalalions? ❑ ❑ E 11 Is GW-59A certification farm completed for facility? 0 0 0 Page 5 of 7 Permit: W00028552 owner - Facility: Old North State Water Company LLC Inspection Date: 0111012020 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up 1s effluent sampled for same parameters as GW? ❑ ❑ M ❑ Do effluent concentrations exceed GW standards? ❑ ❑ ■ ❑ Are annual soil reports available? ❑ ❑ ❑ # Are PAN records required? ❑ ❑ 0 ❑ # Did last soil report indicate a need for lime? ❑ ❑ ❑ If so, has it been applied? ❑ ❑ ❑ Are operational logs present? 0 ❑ ❑ ❑ Are lab sheets available for review? E ❑ ❑ ❑ Do lab sheets support data reported on NDMR? E ❑ ❑ ❑ Do lab sheets support data reported on GW-59s? ❑ ❑ M ❑ Are Operational and Maintenance records present? E ❑ ❑ ❑ Were Operational and Maintenance records complete? 0 ❑ ❑ ❑ Has permittee been free of public complaints in last 12 months? ❑ E ❑ ❑ Is a copy of the SOC readily available? ❑ ❑ so No treatment units bypassed since last inspection? ❑ ❑ 0 ❑ Comment: Com faints from residents still being received by RRO. Con'unctive ini ation not being re orled on NDMR for PP1002. End Use -Irrigation Yes No NA NE Are buffers adequate? E ❑ ❑ ❑ Is the cover crop type specified in permit? N ❑ ❑ ❑ Is the crop cover acceptable? 0 ❑ ❑ ❑ Is the site condition adequate? E ❑ ❑ ❑ Is the site free of runoff / ponding? 0 ❑ ❑ ❑ Is the acreage specified in the permit being utilized? 0 ❑ ❑ ❑ Is the application equipment present? 0 ❑ ❑ ❑ Is the application equipment operational? N ❑ ❑ ❑ Is the disposal field free of limiting slopes? 0 ❑ ❑ ❑ Is access restricted and/or signs posted during active site use? 0 ❑ ❑ ❑ Are any supply wells within the CB? ❑ ❑ ❑ Are any supply wells within 250' of the CB? ❑ ❑ ❑ How close is the closest water supply well? ❑ ❑ ❑ Is municipal water available in the area? ❑ ❑ ❑ E # Info only: Does the permit call for monitoring wells? ❑ ❑ E ❑ Are GW monitoring wells located properly wl respect to IRS and CB? ❑ ❑ No Are GW monitoring wells properly constructed, including screened interval? ❑ ❑ 0 ❑ Are monitoring wells damaged? ❑ ❑ 0 ❑ Page 6 of 7 Permit: WO0028552 Owner • Facility: Old North State Water Company LLC Inspection Data: 01/1012020 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up Comment: Page 7 of 7