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HomeMy WebLinkAboutNC0036196_Inspection_20220531ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director James Wentz City of Newton Post Office Box 550 Newton, North Carolina 28658 NORTH CAROLINA Environmental Quality May 31, 2022 SUBJECT: Pretreatment Compliance Inspection City of Newton NPDES Permit No. NC0036196 Catawba County Dear Mr. Wentz: Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Newton's Industrial Pretreatment Program on May 18, 2022, by Mr. Wes Bell of this Office. Please advise the City's Pretreatment staff of our findings by forwarding the enclosed report. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell@ncdenr.gov. Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche DE Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION 1. Control Authority (POTW) Name: City of Newton 2. Control Authority Representative(s): Eric Jones, Stacy Rowe, McKenna Blevins 3. Title(s): WWTP Superintendent, Chief Operator, Pretreatment Coordinator 4. Last Inspection Date: 7/27/21 Inspection Type: ❑ 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: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA PCS CODING Main Program Permit Number NC0036196 MM/DD/YY 05/18/2022 7. Current Number Of Significant Industrial Users (SIUs)? 2 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)? 2 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 either of the Last 2 Semi -Annual Periods? Not Been Published for Public Notice?(May refer to PAR if Excessive SIUs in SNC) SNC for SNC for 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? /1 YES ❑ NO See Comments Section ❑ YES /1 NO Limits: None Reporting: None )lished: N/A N/A ❑ YES /1 NO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES 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 26. If NO to 23 - 26, list violations: 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO ❑ NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW Program Element Clark Creek WWTP (NC0036196) Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/10/17 /1 Yes ❑ No 6/6/19 /1 Yes ❑ No 10/1/22 Industrial Waste Survey (IWS) 10/24/19 /1 Yes ❑ No 3/4/20 /1 Yes ❑ No 10/1/24 Sewer Use Ordinance (SUO) 12/18/12 /1 Yes ❑ No 2/11/13 /1 Yes ❑ No Enforcement Response Plan (ERP) 10/28/19 0 Yes ❑ No 2/5/20 /1 Yes ❑ No Long Term Monitoring Plan (LTMP) 6/30/15 a Yes ❑ No 8/5/15 /1 Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 29. User Name 1. Technibilt 2. Special Metals 3. 30. IUP Number 1018 1015 31. Does File Contain Current Permit? /1 Yes ❑ No /1 Yes ❑ No ❑ Yes ❑ No 32. Permit Expiration Date 7/31/25 7/31/25 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 471.35 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? /1 Yes ❑ No /1 Yes ❑ No ❑ Yes ❑ No 35. Does File Contain an Inspection Completed Within Last Calendar Year? A Yes ❑ No /1 Yes ❑ No ❑ Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) a. ►NYes •No b. •Yes ■No a. ►NYes ■No b. •Yes ■No a. •Yes •No b. •Yes ■No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? ®Yes❑No❑N/A ❑Yes❑NoNN/A ❑Yes❑No❑N/A 38. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. ►NYes ■No b.❑Yes❑No®N/A a. ►NYes ■No b.❑Yes❑NoNN/A a. •Yes MN() b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? A Yes ❑ No /1 Yes ❑ No ❑ Yes ❑ No 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? /1 Yes ❑ No /1 Yes ❑ No ❑ Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP, including flow? ®Yes❑No❑N/A NYes❑No❑N/A ❑Yes❑No❑N/A 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports on time? NYes❑No❑N/A NYes❑No❑N/A ❑Yes❑No❑N/A 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? NYes❑No❑N/A ❑Yes❑NoNN/A ❑Yes❑No❑N/A 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? ❑Yes❑NoNN/A NYes❑No❑N/A ❑Yes❑No❑N/A 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? NYes❑No❑N/A ❑Yes❑No❑N/A ■ Yes • No L NA 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑Yes❑NoNN/A NYes❑No❑N/A ❑Yes❑No❑N/A 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 c. Did POTW resample within 30 days of knowledge of SIU limit Days? a.❑Yes❑NoNN/A b.❑Yes❑NoDN/A e.❑Yes ❑No®N/A a.®Yes❑No❑N/A b.❑Yes❑No®N/A o.❑Yes❑No®N/A a.❑Yes ❑No❑N/A b.❑Yes ❑No❑N/A c.❑Yes ❑No❑N/A violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes /1 No ❑ Yes r No ❑ Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? ❑Yes❑NoNN/A NYes❑No❑N/A ❑Yes❑No❑N/A 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑No❑N/A 49. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? a.❑Yes ❑NoNN/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes ❑NoNN/A a.❑Yes ❑No❑N/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes /1 No ❑ Yes L No ❑ Yes ❑ No NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 Requested Information For You? FILE REVIEW COMMENTS: 17. An effluent total residual chlorine daily maximum limit violation was reported in November 2021. 20. Special Metal's Consent Order expired on 1/21/22. 25. Overall, all effluent LTMP analyses were reported on the eDMRs; however, effluent zinc results were not included. 35. The POTW performed the SIU inspections on 9/30/21 (Technibilt) and 7/27/21 (Special Metals). 39. The POTW's on -site certified laboratory analyzes BOD, TSS, ammonia, COD, and pH. Meritech Labs has been contracted to perform all remaining LTMP and SIU analyses. 41a. Technibilt and Special Metals both contract Pace Analytical Services to perform IUP analyses. 46. The POTW issued NOVs to Special Metals for chromium IUP limit violations in August and November 2021 and nickel IUP limit violations in July, August and September 2021. Special Metals was also issued NOVs for the failure to monitor fluoride during the fourth quarter of 2021 and chromium and nickel during the week of 7/12/21 — 7/16/21. Technibilt was issued a NOV for the failures to monitor pH during July 2021; however, the POTW will need to verify if the SIU did violate the IUP pH monitoring requirement. SUMMARY AND COMMENTS: The records reviewed during the inspection were organized and well maintained. The POTW must ensure the nickel reporting level (Meritech and Pace Analytical Services) and cyanide reporting level (Pace Analytical Services) is at or below the required IUP reporting levels. The POTW will need to amend all applicable eDMRs to include the effluent zinc results. In addition, the POTW must rescind the NOV to Technibilt for pH monitoring violations (January, June and July 2021) if the SIU did meet the IUP's monitoring requirement following verification. Overall, the POTW's Industrial Pretreatment Program was being properly implemented. NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ PCI COMPLETED BY: PCI REVIEWED BY: —DocuSigned by: '—A61606D9OCC3437_. DATE: 5/31/2022 Wes Bell, Environmental Specialist 11, MRO/WQROS, DWR E—DocuSigned by: '—A14CC681AF27425... DATE: 5/31/2022 Corey Basinger, Regional Supervisor, MRO/WQROS, DWR NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3