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HomeMy WebLinkAboutNC0021121_202308PCI_20230912ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Mitch Williams Public Works Director 300 South Main Street Mount Airy, NC 27030 NORTH CAROLINA Environmental Quality September 12, 2023 SUBJECT: Pretreatment Compliance Inspection (PCI) City of Mount Airy WWTP Main Program Permit (NPDES) #NC0021121 Surry County Dear Mr. Williams: On 8/31/2023 a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery & Jesse Barnes of the Winston-Salem Regional Office. Chris Marion was present for the inspection. The purpose of this inspection was to determine the effectiveness of the City's pretreatment program, which includes reviewing the files, POTW plant performance, industry monitoring data, and adherence to the enforcement response plan (ERP). Background This is a 7 MGD permitted facility. The city has 1 Significant Industrial User (SILT). The publicly owned treatment works (POTW) had no violations in 2022. POTW Interview Permittee is awaiting approval of HWA (submitted 4/21/21). IWS is due 10/31/2023. Mr. Marion is preparing to submit IWS soon for review and approval. Mr. Marion notes no interference to WWTP from industrial discharge. Mr. Marion's help was much appreciated during PCI and has demonstrated thorough knowledge of the program. No violations or items of concern were noted in the inspection. Pretreatment Program Elements Review The Headworks Analysis (HWA) was submitted on 4/23/2021 and is awaiting approval. The next HWA is TBA. The IWS was last approved on 1/7/2019. The next IWS is due 10/31/2023. The Sewer Use Ordinance (SUO) was approved on 10/25/2012. The Enforcement Response Plan (ERP) was submitted on DATE and approved on 2/5/2020. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm The Long -Term Monitoring Plan (LTMP) was submitted 11/30/2021 and approved on 12/15/2021. LTMP File Review The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies (2/year). LTMP files are in good order and organized well. Texwipe is sampled in January and July. All data from LTMP is recorded accurately on DMR. Industrial User Permit (IUP) File Review IUP files are in good order and organized very well. No discrepancies were found during inspection. A review of the file for Texwipe (IUP #0001) revealed that the monitoring data was well organized and compliant. Texwipe is non -categorical. Daily flow reports indicate a range of 50,000 — 200,000 gallons per day is discharged to WWTP (-100,000 average). Texwipe manufactures polyester fabric that is used for consumer wipe products (ie: sanitary, automotive, computer, medical and industrial). No slug/spill control plan is needed. Self-contained area with engineering controls in place to prevent accidental release to WWTP. Action Items No other action items were noted. The pretreatment program is considered satisfactory. Chris Marion runs an excellent pretreatment program. If you have any questions, please contact Tricia Lowery or me at (336) 776-9800. Sincerely, DocuSigned by: 145B49E225C94EA... Lon T. Snider Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO Attachment: 1. NC DWR Pretreatment Compliance Inspection (PCI) Report ec: Chris Marion, City of Mount Airy/WWTP Supervisor REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: City of Mount Airy 2. Control Authority Representative(s): Chris Marion 3. Title(s): WWTP Supervisor and PT Coordinator 4. Last Inspection Date: 8/11/2022 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: Are Milestone Dates Being Met? ❑ YES ❑ NO ICIS CODING Main Program Permit Number MM/DD/YY I N I C 1 0 1 0 1 2 1 1 1 1 1 2 1 1 1, 1 2 1 28 1 25 1 Exp date 7. Current Number Of Significant Industrial Users SIUs ? 1 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 ? 0 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 Put 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: na Reporting: na dished: na None ❑ 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! LTMP samples are collected in January and July and placed on DMR. 26. If NO to 23 - 26, list violations 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 If yes, which ones? Eliminated: Added: 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) 4/23/21 ® Yes ❑ No ** ❑ Yes ❑ No ** Industrial Waste Survey IWS 10/30/18 ® Yes ❑ No 1/7/19 ® Yes ❑ No 10/31/23 Sewer Use Ordinance SUO 9/26/12 ® Yes ❑ No 10/25/12 ® Yes ❑ No -- Enforcement Response Plan (ERP) 1/13/20 ® Yes ❑ No 2/5/20 ® Yes ❑ No -- Long Term Monitoring Plan (LTMP) 11/30/21 ® Yes ❑ No 12/15/21 ® Yes ❑ No -- INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 iU INSPECTION) 29. User Name 1. Tex 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? ® Yes ❑ No ❑ Yes ❑ No l ❑ Yes ❑ No 32. Permit Expiration Date 6/30/27 33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A N/A 34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No El Yes El No El Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No I ❑ Yes ❑ No I ❑ Yes ❑ N­T11 36. a. Does the File Contain a Slug/Spill Control Plan? a. ❑Yes NNo a. ❑Yes ❑No a. ❑Yes ❑No b. If No, is One Needed? See Inspection Form from POTW b. ❑Yes NNo 11 b. ❑Yes ❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan TOMP ? 38. a. Does File Contain Original Permit Review Letter from the Division? a. NYes ❑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 ElYes Elo N ❑ Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No ji ❑ Yes ❑ No ii 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its ❑Yes❑NoON/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 ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Re ortin Non-Com liance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. If applicable, Did POTW resample within 30 days of becoming aware c.❑Yes❑No®N/A of SIU limit violations in the POTW's sampling of the SIU? 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 ❑ Yes ❑ No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP OVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoON/A I ❑Yes❑No❑N/A I ❑Yes❑No❑N/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A II ❑Yes❑No❑N/A II ❑Yes❑No❑N/A II 50. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/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 El Yes ElNo Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: IUP file is in good order and organized very well. No discrepancies were found during inspection. ** Permittee is awaiting approval of HWA (submitted 4/21/21). IWS is due 10/31/2023. Mr. Marion is preparing to submit IWS soon for review and approval. LTMP files are in good order and organized well. Texwipe is non -categorical. Daily flow reports indicate a range of 50,000 — 200,000 gallons per day is discharged to WWTP (-100,000 average). Mr. Marion notes no interference to WWTP from industrial discharge. Texwipe manufactures polyester fabric that is used for consumer wipe products (ie: sanitary, automotive, computer, medical and industrial). No slug/spill control plan is needed. Self-contained area with engineering controls in place to prevent accidental release to WWTP. INDUSTRY INSPECTION Main Program Permit Number MM/DD/YY 1. Industry Inspected: 2. Industry Address: 3. Type of Industry/Product: 4. Industry Contact: Phone: 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: NO AUDIT CONDUCTED OVERALL SUMMARY AND COMMENTS: Comments: Requirements: Recommendations: NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Tricia Lowery & Jesse Barnes DATE: 8/31/2023 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3