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HomeMy WebLinkAboutNC0023906_Pretreatment Compliance Inspection_20200925 (2)ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Mr. Jimmy Pridgen Water Reclamation Manager City of Wilson P.O. Box 10 Wilson, NC 27894-0010 NORTH CAROLINA Environmental Quality September 25, 2020 Subject: Pretreatment Compliance Inspection City of Wilson - Hominy Creek Wastewater Management Facility NPDES Permit No. NCO023906 Wilson County Dear Mr. Pridgen: On August 28, 2020, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment Compliance Inspection of City of Wilson's pretreatment program. The assistance given by Ms. Laura Pruitt, the Water Reclamation Compliance Coordinator, was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: 1. The City has 11 Significant Industrial Users (SIUs), 9 of which are also Categorical Industrial Users (CIUs). It was noted that no SIUs were in Significant Non -Compliance (SNC) during the last two semi-annual periods. 2. The pretreatment inspection file review included Bridgestone (Permit No. 8412), Sun River (Permit No. 2009-020) and UTC/Kidde (Permit No. 8402). The files needed for review were available for inspection, contained all the required elements and were in excellent condition. All three SIUs were compliant during the most recent 6-month period. A review of the files containing the pretreatment program elements was conducted. All files were available and up to date. Enforcement Response Plan and Long Term Monitoring Plan were updated and approved recently. 4. LTMP data were reviewed, it was noted that all parameters were sampled at required locations and analyzed with required detection levels. LTMP data was well organized and maintained. norDE Q�� North Carolina Department of Environmental Quality I Division of Water Resources r rnani wa Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 oep,m ,t ie n��menni"i;� 919.791.4200 Thank you for your continued support of the Pretreatment Program. If you have any questions or comments, please call Cheng Zhang at (919) 791-4200 (or email: cheng.zhang@ncdenr.gov). Sincerely, DocuSigned by: Uaun,c,SSa -E. 62916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Enclosure: City of Wilson PCI Inspection Form CC: Central Files w/attachment (Laserfiche) Cheng Zhang, RRO Laura Pruitt, City of Wilson (Electronic copy only) NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION [Complete Prior To PCI; Review Prollram Info Database Sheet(s)] 1. Control Authority (POTW) Name: City of Wilson 2. Control Authority Representative(s): Laura Pruit 3. Title(s): Water Reclamation Compliance Coordinator 4. Last Inspection Date: 9/22/2018 Inspection Type (Check One): ❑ PCI ® Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO Order Type, Number, Parameters: ICIS CODING Main Program Permit Number I N I C 1 0 10 1 21 31 91 01 6 MM/DD/YY 1081281201 Are Milestone Dates Being Met? ❑ YES ❑ NO 7. Current Number Of Significant Industrial Users (SIUs)? 11 8. Number of SIUs With No IUP, or With an Expired IUP? 0 9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0 10. Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0 11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods? 0 12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods? 0 13. Number of SIUs in SNC with Pretreatment Schedule? 0 14. Number of SIUs on Schedules? 0 15. Current Number Of Categorical Industrial Users (CIUs)? 9 16. Number of CIUs in SNC? 0 POTW INTERVIEW 17. Since the Last PCI, has the POTW had any NPDES Limits Violations? If Yes, What are the Parameters and How are these Problems Being Addressed? 18. Since the Last PCI, has the POTW had any Problems Related to an Industrial Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased Sludge Production, Etc.)? If Yes, How are these Problems Being Addressed? 19. Which Industries have been in SNC for Limits or Reporting during SNC for either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul 20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an Order, Has a Signed Copy of the Order been sent to the Division? 21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? [—]YES ® NO ❑ YES ®NO Limits: None Reporting: None Ilished: None N/A ❑ YES ® NO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO 25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself. 26. IfNO to 23 - 26, list violations 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info: Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 3/29/2018 ® Yes ❑ No 6/5/2018 ® Yes ❑ No 4/1/2023 Industrial Waste Survey (IWS) 5/30/2019 ® Yes ❑ No 8/15/2019 ® Yes ❑ No 6/1/2024 Sewer Use Ordinance (SUO) 2/12/2012 ® Yes ❑ No 3/12/2012 ® Yes ❑ No Enforcement Response Plan (ERP) 2/12/2020 ® Yes ❑ No 2/14/2020 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 1 2/12/2020 ® Yes ❑ No 4/3/2020 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Bridgestone 2. Sun River IF 3. UTC/Kidde 30. IUP Number 1 8412 F 2009-020 8402 31. Does File Contain Current Permit? ® Yes ❑ NoI ® Yes ❑ NoI ® Yes ❑ No 32. Permit Expiration Date 12/31/2024 6/30/2023 12/31/2023 33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A 428A N/A 433 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? I ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? a. ❑Yes ®No a. ®Yes ❑No a. ❑Yes ®No b. If No, is One Needed? (See Inspection Form from POTW) b. El ENo b. ❑Yes ❑No b. ❑Yes ENo 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A Organic Management Plan TOMP ? 38. a. Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No a. ®Yes []No a. ®Yes ❑No b. All Issues Resolved? b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ®Yes ❑ No ® Yes ❑ No ®Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? I ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports EYes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A All Reporting Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑NoEN/A a.❑Yes❑NoEN/A a.❑Yes❑NoEN/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.❑Yes❑NoEN/A b.❑Yes❑NoEN/A b.❑Yes❑NoEN/A c. If applicable, Did POTW resample within 30 days of becoming aware of SIU limit violations in the POTW's sampling of the SIU? c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No 11 ❑ Yes ® No 11 ❑ Yes ® No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 50. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑NoEN/A a.❑Yes❑NoEN/A a.❑Yes❑NoEN/A b. IS SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ® No ❑ Yes ® No Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: All three SIUs were in compliance during the period reviewed. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number 1. Industry Inspected: 2. Industry Address: 3. Type of Industry/Product: 4. Industry Contact: Phone: MM/DD/YY Fax: Title: 5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ YES ❑ NO 6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? Comments: A. Initial Interview ❑ YES ❑ NO B. Plant Tour ❑ YES ❑ NO C. Pretreatment Tour ❑ YES ❑ NO D. Sampling Review ❑ YES ❑ NO E. Exit Interview ❑ YES ❑ NO Industrial Inspection Comments: OVERALL SUMMARY AND COMMENTS: Comments: The program is well managed. Requirements: None Recommendations: None NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 28, 2020 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3