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HomeMy WebLinkAboutNC0026123_Compliance Evaluation Inspection_20180426 ROY COOPER .3 Gotier nor MICHAEL S.REGAN Secretarl, Water Resources LINDA CULPEPPER Environmental Quailt} InterimDoecror April 26,2018 Michele Dawes City of Asheboro P.O. Box 1106 Asheboro,NC 27204 SUBJECT: Pretreatment Compliance Inspection (PCI) RECEIVED/DENIR/DWR City of Asheboro NPDES#NC0026123 MAY 10 2018 Randolph County Water Resources Dear Ms. Dawes Permitting Section On April 11, 2018 a Pretreatment Compliance Inspection (PCI)was performed by Jim Gonsiewski of the Winston-Salem Regional Office.Ms.Michelle Dawes,Pretreatment Coordinator for the City of Asheboro, and Sara Laughlin,Technical Services Specialist for the City of Asheboro,were present for the inspection. The purpose of this inspection was to determine the effectiveness of the Town'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 9 MGD permitted facility The City has sixteen(16)Significant Industrial Users(SIUs),seven(7) of which are categorical. The publicly owned treatment works (POTW) has not had any limits violations since the last pretreatment compliance inspection. POTW Interview There are no plant problems related to pretreatment issues and there are no NPDES permit limit or monitoring violations recorded from January 2017 through February 2018. The facility is very well operated. Pretreatment Program Elements Review The Headworks Analysis(HWA)renewal was submitted on March 23,2017. The HWA was approved on June 30, 2017.The next HWA is due on June 1, 2022. The last Industrial Waste Survey(IWS)was submitted on April 11,2013. This IWS was approved on June 10, 2013. The next IWS was due on April 15, 2018. At the time of the inspection, a new IWS had been completed and was being prepared for submittal. The Sewer Use Ordinance(SUO)was approved on November 5,2012. The Enforcement Response Plan(ERP)was approved on August 12,2013. The Long Term Monitoring Plan(LTMP)was approved on March 4, 2016. Nothing Comparts7-... State of North Carolina I Environmental Quality 450 W Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105 Phone 336-776-98001 FAX 336-776-9797 o~ a LTMP File Review The Long Term Monitoring Plan(LTMP)is being conducted at the proper locations and frequencies. Industrial User Permit(IUP)File Review A review of the file for Kayser Roth (#1222) revealed that the monitoring data was well organized and compliant. A review of the file for Randolph Packing (#0320) revealed that the monitoring data was well organized and compliant. A review of the file for Energizer H (#4136) revealed that the monitonng data was well organized and compliant The slug control plan for Kayser Roth(#1222)was in good order. The slug control plan for Energizer II(#4136)was in good order. Action Items No other action items were noted The pretreatment program is considered satisfactory Ms Dawes implements the pretreatment program in an excellent manner. If you have any questions please contact Jim Gonsiewski or me at(336)776-9800 Sincerely, d ui��� V ' i J Sherri V.Knight,PE Regional Supervisor Water Quality Regional Operations Section Division of Water Resources,NCDEQ—WSRO cc• PERCS Unit—Monti Hassan Central Files WSRO Files . ; NORTH CAROLINA DIVISION OF WATER RESOURCES . PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT /raterRes,urces N V RONYENrpL PLA..I Y r BACKGROUND INFORMATION(Complete Prior To PCI;Review Program Info Database Sheet(s)1 1. Control Authority(POTW)Name. iN'N \ e � „`ye 2. Control Authority Representative(s): C,'j ©-F Ir-1_S h4 h <,) 3. Title(s): e a4-1 c v * E o rrA,l ,Arlf (' 4. Last Inspection Date• (01/x7/4e, Inspection Type(Check One): ❑ PCI [Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? [l'fES ❑NO 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑YES RIO Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑YES ❑NO ICIS CODING Main Program Permit Number MM/DD/YY NICIO 10 1 �1(.12II 1(4- I - 1. I Ii'tl 7. Current Number Of Significant Industrial Users(SIUs)? 8. Number of SIUs With No IUP,or With an Expired IUP? 9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? c� 10.Number of SIUs Not Sampled By POTW m the Last Calendar Year? 11.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods'? C7 12 Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 7) 13 Number of SIUs in SNC with Pretreatment Schedule' F) 14 Number of SIUs on Schedules? (� 15.Current Number Of Categorical Industrial Users(CIUs)? '7 16 Number of ClUs in SNC? POTW INTERVIEW 17 Since the Last PCI,has the POTW had any NPDES Limits Violations'? ❑YES Er5f0 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 ❑YES 12-go 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 Limits either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting Nov\ Public Notice?(May refer to PAR if Excessive Sills in SNC) Not Published 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? Non E 21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES gNO Ones? LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Bemg Conducted at Appropriate Locations and Frequencies'? &I YES ❑NO 23. Are Correct Detection Levels being used for all LTMP/STMP Momtormg? A YES ❑ NO 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? EYES ❑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 If NO 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. err,rlrim n-,.._...............n,......�i.....,.,.r_......,......_ �n!''T�L'....... TTnrlo+orl Tlanprn1,...')1114 P'rn 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 Pro am Info. Program Element Last Submittal Last Approval Date Next Due, Date In file? Date In file If Applicable Headworks Analysis(HWA) )/.).3/1-7 ©Yes❑ No (p j 3 of I'l [?Yes❑ No 43./1/ Industrial Waste Survey(IWS) y f l 1 i3 2 Yes❑ No (.9 f(o(!3 ©Yes❑ No I 1S-1 Sewer Use Ordinance(SUO) 1 0(a3 f la RI Yes❑ No (- 1'. Q Yes❑ No Enforcement Response Plan(ERP) I, L/(13 ®Yes❑ No $I I / 2 Yes❑ No Long Term Monitoring Plan(LTMP) i) -( ) g Yes ❑ No 3 i ) f, [a Yes❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 1UP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29 User Name 1 0. Se-c PC+ 2‘Ro.nok i:41 etc. ►n 3 (-'he.� i 7_e-f'�� 30. IUP Number b 3 `-f 13 31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No 0„Yes ❑ No 32 Permit Expiration Date '713)td a 33. Categorical Standard Applied(LE.40 CFR,Etc.)CT N/A 34. Does File Contain Permit Application Completed Within One Year Prior IR Yes ❑ No [-Yes ❑ No JYes ❑ No to Permit Issue Date? 35 Does File Contain an Inspection Completed Within Last Calendar Years 15/Yes ❑ No a Yes ❑ No _ ,21 Yes ❑ No 36 a Does the File Contain a Slug/Spill Control Plan a.'1Wes No a. ❑Yes ElNo a ,Yes ONo b.If No,is One Needed?(See Inspection Form from POTW) b ❑Yes ONo b. ❑Yes EINo b. ['Yes ONo 37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoyN/A ❑Yes❑NoRN/A ❑Yes❑NoJN/A Organic Management Plan(TOMP)9 38 a.Does File Contain Original Permit Review Letter from the Division? a JEYes ONo a.,p Yes ONo a'Wes ❑No b.All Issues Resolved') b❑Yes❑NegN/A b❑Yes❑N9 /A b,3cYes❑No❑N/A 39. During the Most Recent Semi-Annual Period,Did the POTW Complete &J Yes ❑ No I Yes ❑ No Yes ❑ No its Sampling as Required by IUP,including flow9 40 Does File Contain POTW Sampling Chain-Of-Custody Forms9 „Yes ❑ No `,R]Yes ❑ No IK Yes ❑ No 41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ❑Yes❑No'pN/A ❑Yes❑NeN/A Yes❑No❑N/A Sampling as Required by IUP,including flow? `"�Plitle.el Coz '`` 41b.During the Most Recent Semi-Annual Period,Did SIU submit all reports ,]Yes❑No❑N/A , (Yes❑No❑N/A Yes❑No❑N/A on time9 42a.For categorical Ms with Combined Wastestream Formula(CWF), does ❑Yes❑NogIN/A ❑Yes❑No{ N/A ❑Yes❑Nod`i/A file include process/dilution flows as Required by IUP? 42b.For categorical Ms with Production based limits,does file include ❑Yes❑No1 1/A ❑Yes❑NoRN/A J 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 X.Yes ❑ No KYes ❑ No El Yes ❑ No All Limits Non-Compliance from Both POTW and SM Sampling? 43b. During the Most Recent Semi-Annual Period,Did:he POTW Identify ❑Yes❑NA1N/A ❑Yes❑No)S,IN/A ❑Yes❑NoRN/A All Reporting Non-Compliance from SM Sampling? 44. a.Was the POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes❑NoN/A a.❑Yes❑Noc l/A a.❑YesONo giN/A Monitoring Violations? b.Did Industry Resample and submit results to POTW Within 30 Days? b❑Yes❑N9$1N/A b❑Yes❑NoN/A b❑Yes❑NoSIN/A c.If applicable,Did POTW resample within 30 days of becommg aware c❑Yes❑N N/A of SM limit violations in the POTW's sampling of the SM? c❑Yes❑No�N/A c❑Yes❑Nof N/A 46 During the Most Recent Semi-Annual Period,Was the SM in SNC7 ❑Yes No aWes y No ❑Yes n.No 47 During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑N N/A ❑Yes❑NopN/A ❑Yes❑No /A as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)7 48 Does the File Contain Penalty Assessment Notices9 ❑Yes❑NojSIN/A ❑Yes❑NoL i/A ❑Yes❑NoI 'l/A 49 Does The File Contain Proof Of Penalty Collection ❑Yes❑Nolg N/A ❑Yes❑Nope N/A ❑Yes0No'1/A 50 a.Does the File Contain Any Current Enforcement Orders9 a.❑Yes❑Nd T/A a.❑Yes❑NoKN/A a.❑Yes❑Nd l/A b.Is SM in Compliance with Order9 b❑Yes❑NSaN/A b❑Yes❑Ngi/A b❑Yes❑NoB[N/A 51 Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes [ No ❑Yes a No ❑Yes [R No Requested Information For You? NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2 / ALE IEEVIEW COMMENTS: INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1.Industry Inspected: 2. Industry Address: 3.Type of Industry/Product. 4.Industry Contact: Title: Phone: Fax: 5.Does the POTW Use the Division Model Inspection Form or Equivalent? ❑YES 0 NO • 6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? Comments: A. Initial Interview 0 YES 0 NO B. Plant Tour 0 YES 0 NO C. Pretreatment Tour ❑YES 0 NO D. Sampling Review 0 YES 0 NO E. Exit Interview ❑YES ❑NO Industrial Inspection Comments: OVERALL SUMMARY AND COMMENTS: r Comments: "�‘i5 �5 � ( Ai � -. A' �e 111 1 � `ac • „A • k 4 r� '►r T l Requirements; Recommendations: NOD: ❑YES ❑NO NOV: ❑YES ❑NO QNCR: ❑YES D NO POTW Rating: Satisfactory >( Marginal UnSatisfactory (Th PCI COMPLETED BY: ` DATE: 4 /)(1 )