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HomeMy WebLinkAboutNC0036196_Inspection_20180531s Water Resources Environmental Quality 31 May 2018 Ms. Stacy Rowe Pretreatment Coordinator City of Newton Post Office Box 550 Newton, North Carolina 28658 Subject: Pretreatment Compliance Inspection City of Newton NPDES Permit No. NCO036196 Catawba County Dear Ms. Rowe: ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of Newton's Industrial Pretreatment Program on May 22, 2018, by Mr. Wes Bell of this Office. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192, or via email at wes.bell@ncdenr.gov. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report cc: Vivien Zhong, PERCS Unit (vivien.Zhong@ncdenr.gov) State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations Mooresville Regional Office 1610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115 704-663-1699 NORTH CAROLINA DIVISION OF WATER RESOURCES K�`r�m S PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL DUALITY BACKGROUND INFORMATION 1. Control Authority (POTW) Name: City of Newton 2. Control Authority Representative(s): Stacy Rowe 3. Title(s): Pretreatment Coordinator 4. Last Inspection Date: 6/14/16 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 MM/DD/YY NCO036196 5/22/18 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 SNC foi either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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 Weekly and Monthly Average effluent TSS violations reported in February 2018. ❑ YES ®NO Limits: None Reporting: None dished: N/A 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 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 28. PRETREATMENT PROGRAM ELEMENTS REVIEW Program Element Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/10/17 ® Yes ❑ No 1/16/18 ® Yes ❑ No 10/1/22 Industrial Waste Survey IWS 11/3/14 ® Yes ❑ No 3/26/15 ® Yes ❑ No 10/1/19 Sewer Use Ordinance (SUO) 12/18/12 ® Yes ❑ No 2/11/13 ® Yes ❑ No ® Yes ❑ No Enforcement Response Plan (ERP) 5/23/16 ® Yes ❑ No 8/18/16 ® Yes ❑ No 35. Does File Contain an Inspection Completed Within Last Calendar Year? Long Term Monitoring Plan (LTMP) 6/30/15 ® Yes ❑ No 8/5/15 ® Yes ❑ No a. ®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? ® Yes ❑ I ® Yes ❑ I ❑ Yes ❑ No 32. Permit Expiration Date 7/31/20 7/31/20 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 471.35 IF - 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? ® Yes ❑ No ® Yes ❑ No 11 ❑ 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. 0 e ❑No b. ❑Yes ❑No I b. []Yes []No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑NoNN/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes ❑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 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ❑Yes❑NONN/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 NYes❑No❑N/A NYes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does NYes❑No❑N/A 1 NYes❑No❑N/A 11 ❑Yes❑No❑N/A 1 file include process/dilution flows as Required b IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoNN/A NYes❑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❑NoENA ❑Yes❑NoNN/A ❑Yes❑No❑N/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❑NoON/A ❑Yes❑No❑N/A All Reporting Non -Compliance 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. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑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 ® No ❑ Yes ® No ❑ Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken 0Ycs0NONN/A ❑YesONONN/A ❑Yes❑No❑N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑YesONo[D ❑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? 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 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ® Yes ❑ No ® Yes ❑No ElYes El No Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: 25. Overall, the POTW was reporting all LTMP effluent data with the exception of copper. Amended edmrs will be resubmitted to the Division to include the effluent copper data. 28. The POTW is working with the PERCS Unit (modifying IUPs) to address an over allocation for Silver. 35. The POTW performed the SIU inspections on 11/8/17 (Technibilt) and 5/10/17 (Special Metals). 39. The POTW's on-site certified laboratory analyzes BOD, TSS, ammonia, COD, and pH. Meritech Labs has been contracted to perform metals, oil & grease, fluoride, and TKN. 41a. Technibilt and Special Metals both contract Pace Analytical Services to perform analyses. 42a. The POTW must ensure to apply the CWF if sampling is only performed at Pipe 01 (combined waste streams). 50. The new Pretreatment Coordinator did have difficulty finding all required information; however, all requested data was ultimately found during the inspection. SUMMARY AND COMMENTS: The cyanide detection level (0.008 mg/L) used by the contracted lab for Technibilt was higher than the required IUP detection level (0.005 mg/L). This IUP detection level should be addressed with the PERCS Unit during the next permit renewal and/or modification process. The Pretreatment Coordinator should continue to organize the Pretreatment documentation to ensure all documentation is accessible for review. In addition, the Pretreatment Coordinator must ensure to submit a modified permit (Special Metals) to the PERCS Unit for review if effluent limitations/monitoring requirements are added for Pipe 02. NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ E�`,�c,96D90=437_ Signed by: Be& PCI COMPLETED BY: DATE: 5/31/2018 Wes Bell, Mooresville Regional Office NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3