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Home My WebLink AboutNC0025445_Compliance Report_20181205 ‘S .L�. ,. va rAe7 Ir�"d1i� ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary LINDA CULPEPPER �a p�p� p�t�/t�6pe Interim Director RECEIVED/DENeVDttVR December 5,2018 DEC 12 2018 Lisa Osthues Pretreatment Coordinator Water Resources City of Randleman Permitting Section 168 Nathan Dudley Road Clinton,NC 28328 , SUBJECT: Pretreatment Compliance Inspection(PCI) City of Randleman NPDES#NC0025445 Randolph County Dear Ms. Osthues: On November 13, 2018 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski. Ms. Lisa Osthues 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, the publicly owned treatment works (POTW)plant performance, industry monitoring data, and adherence to the enforcement response plan(ERP). Background This is a 1.745 MGD permitted facility. The City has two (2) Significant Industrial Users which are non- categorical. The POTW has had exceedances of lead. The source of this constituent has been identified as residential piping (ductile iron). The city is surveying the residential areas and one (1) area has been identified as a possible source. The City will develop a remedial plan to eliminate the problem which may include replacing piping and fixtures. POTW Interview There are no plant problems related to pretreatment issues and there are no NPDES permit limit or monitoring violations recorded from November 2017 through November 2018 except for the lead mentioned above. The facility is very well operated. Pretreatment Program Elements Review The Headworks Analysis (HWA) renewal was submitted on May 9, 2017. The HWA was approved on August 16, 2017.The next HWA is due on June 1,2022. ODE Q,) NORTH CAROLINA OTPNI.Nd at Emlrmarealtl Matt North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103 336.776.9800 J The last Industrial Waste Survey(IWS)was submitted on March 2,2018. The IWS was approved on May 25,2018.The next IWS is due on February 28,2023. The Sewer Use Ordinance(SUO)was approved on February 4,2013. The Enforcement Response Plan(ERP)was approved on June 10,2009. The Long Term Monitoring Plan(LTMP)was approved on October 10,2011. 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 Commonwealth Hosiery (#0001) revealed that the monitoring data•was well organized and compliant. A review of the file for Deep River Dyeing(#0004) revealed that the monitoring data was well organized and compliant. The slug control plans for Commonwealth Hosiery(#0001)were in good order. The slug control plans for Deep River Dyeing(#0004)were in good order. Action Items No other action items were noted. The pretreatment program is considered satisfactory. Ms. Osthues maintains an excellent pretreatment program. If you have any questions please contact Jim Gonsiewski or me at(336)776-9800. Sincerely, 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 Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION(Complete Prior To PCI;Review Program Info Database Sheet(s)1 1. Control Authority(POTW)Name: City of Randleman 2. Control Authority Representative(s): Lisa Osthues 3. Title(s):Contract Pretreatment Coordinator 4. Last Inspection Date: 11/15/2017 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 J N 1 C 1 0 1 0 1 2 1 5 1 4 1 4 15 1 1 11 1 13 1 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)? 0 16. Number of ClUs in SNC? 0 POTW INTERVIEW 17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ®YES ❑ NO If Yes,What are the Parameters and How are these Problems Being Addressed? BOD. Air upgrades to the system have been completed and the POTW is meeting BOD limits. Aeration Basin#2 needs repair. This repair has been scheduled. 18. Since the Last PCI,has the POTW had any Problems Related to an Industrial 1 YES ❑ NO Discharge(Interference,Pass-Through,Blockage, Citizens' Complaints,Increased Sludge Production,Etc.)? Lead—it is still being investigated. If Yes,How are these Problems Being Addressed?A corrective action plan is in place. 19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits.None either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting None Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: N/A 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? None 21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ® NO Ones? 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 NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 1 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑YES ® NO � 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 Last Approval Date Next Due, Date In file? Date In file If Applicable Headworks Analysis(HWA) 05/19/2017 ® Yes ❑ No 08/16/2017 ®Yes ❑ No 06/01/2022 Industrial Waste Survey(IWS) 03/02/2018 ®Yes ❑ No 05/25/2018 ® Yes ❑ No 02/28/2023 Sewer Use Ordinance(SUO) 01/03/2013 ®Yes ❑ No 02/04/2013 ®Yes ❑ No Enforcement Response Plan(ERP) 04/21/2009 ®Yes ❑ No 06/10/2009 ® Yes ❑ No Long Term Monitoring Plan(LTMP) 09/16/2011 ® Yes ❑ No 10/10/2011 ® Yes ❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Commonwealth Hosiery 2.Deep River Dyeing 3. 30. IUP Number 0001 0004 31. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ No ❑Yes ❑ No 32. Permit Expiration Date 12/31/21 12/31/21 33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or NiA ---- ---- 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 ❑ Yes ❑ No 36. a.Does the File Contain a Slug/Spill Control Plan? a. ®Yes ❑No a. ZYes ❑No a. ['Yes ['No b. If No,is One Needed?(See Inspection Form from POTW) b. ['Yes ❑No b. ❑Yes❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑NoSN/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❑NoSN/A b❑Yes❑NoSN/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? ® 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 ®Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical Ws with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A file include process/dilution flows as Required by IUP? 42b.For categorical Ns with Production based limits,does file include ❑Yes❑No®N/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? N/A N/A 43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®N/A ❑Yes❑No®N/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❑NoSN/A a.❑Yes❑NoSN/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b❑Yes❑NoSN/A b❑Yes❑NoSN/A b.❑Yes❑No❑N/A c.If applicable,Did POTW resample within 30 days of becoming aware c❑Yes❑NoSN/A of SIU limit violations in the POTW's sampling of the SIU? c❑Yes❑NoSN/A c❑Yes❑No❑N/A 46. During the Most Recent Semi-Annual Period, Was the SIU in SNC? ❑ Yes ® No ❑ Yes ® No ❑Yes ❑ No 47. During the Most Recent Semi-Annual Period, Was Enforcement Taken ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP(NOVs,Penalties,timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A 50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑NoSN/A a.❑Yes❑NoSN/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b❑Yes❑NoSN/A b❑Yes❑NoSN/A b❑Yes❑No❑N/A NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2 51. Didythe POTW Representative Have Difficulty in Obtaining Any of This El Yes ® No ❑ Yes ® No ❑Yes ❑ No Requested Information For You? FILE REVIEW COMMENTS: The City of Randleman has divided the City into areas and has been checking for high lead levels since July 2018. This has been planned as a 5-year study. One(1)neighborhood has been identified as a possible source. After the source is identified,the next stage may be replacing piping and fixtures. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY J I I II I I I II I I I 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 El NO 6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? Comments: A. Initial Interview ❑ YES El 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: A very well run program. Requirements: Recommendations• NOD: ❑ YES ®NO NOV: El YES ®NO QNCR: ❑YES ®NO POTW Rating: Satisfactory X Marginal Unsatisfactory PCI COMPLETED BY: Jim Gonsiewski DATE: I � NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3