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HomeMy WebLinkAboutNC0024244_Inspection_20191115ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. Brandon Plyler WWTP Supervisor/Pretreatment Coordinator City of Albemarle Post Office Box 190 Albemarle, North Carolina 28002-0190 Dear Mr. Plyler: NORTH CAROLINA Environmental Quality 15 November 2019 Subject: Pretreatment Audit Inspection City of Albemarle NPDES Permit No. NCO024244 Stanly County Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Albemarle's approved Industrial Pretreatment Program on November 5, 2019, by Mr. Wes Bell of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell(c�r�,ncdenr.gov. Sincerely, DocuSSiignneed by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report D Q � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROLINA Da"MoM a enWmn�bl mwnq 704,663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Background Information: 1. Control Authority (POTW) Name: City of Albemarle 2. Control Authority Representative(s): Brandon Plyler, Nadine Blackwell 3. Title(s): WWTP ORC/Pretreatment Coordinator, Consultant/SUEZ 4. Address of POTW: Street/Post Office Box Post Office Box 190 City/State/Zip Code Albemarle, NC 28002-0190 Phone Number: (704) 984-9634 Fax Number: 704-984-9606 (City Hall) E-Mail: bplyler@albemarlenc.gov 5. Audit Date: 11/05/2019 6. Last Inspection Date: 12/08/2017 Inspection Type: ® PCI ❑ Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® Yes ❑ No If No, Explain. 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No If Yes, Explain. See File Comments Section. 9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA Parameters Covered Under Order ICIS Coding: Main Program Permit Number MM/DD/YY 1� C1 01 01 21 41 21 41 4j 111 1 05 119 10. .................................................................................................................................................................................................................................................................................................... Current Number of Significant Industrial Users (SIDS)? 1 11. .................................................................................................................................................................................................................................................................................................... Number of SIUs with No IUP, or with no Expired IUP? 0 12. .................................................................................................................................................................................................................................................................................................... Number of SIUs Not Inspected by POTW in Last Calendar Year? 0 13. .................................................................................................................................................................................................................................................................................................... Number of SIUs Not Sampled by POTW in Last Calendar Year? 0 14. .................................................................................................................................................................................................................................................................................................... Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods? 0 15. .................................................................................................................................................................................................................................................................................................... Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? 0 16. .................................................................................................................................................................................................................................................................................................... Number of SIUs in SNC with Pretreatment Schedule? 0 17. .................................................................................................................................................................................................................................................................................................... Number of SIUs on Schedules? 0 18. Current Number of Categorical Industrial Users (CIUs)? 0 19. Number of CIUs in SNC? 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 20. PRETREATMENT PROGRAM ELEMENTS REVIEW: Program Element: NCO024244 Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/21/14 ® Yes ❑ No 1/12/15 ® Yes ❑ No 12/31/19 Industrial Waste Survey (IWS) 6/28/16 ® Yes ❑ No 9/19/16 ® Yes ❑ No 4/30/21 Sewer Use Ordinance (SUO) 12/27/12 ® Yes ❑ No 1/10/13 ® Yes ❑ No Enforcement Response Plan (ERP) 6/25/08 ® Yes ❑ No 9/12/08 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 2/5/19 ® Yes ❑ No 4/2/19 ® Yes ❑ No Legal Authority (Sewer Use Ordinance-SUO) 21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? ® Yes ❑ No If yes, Please list these towns and/or areas. Stanly County 22. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA A copy, if not already submitted, should be sent to Division. 23. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA If yes, Explain. 24. Date of Last SUO Adoption by Local Council 2/17/14 25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 26. Did you send a copy of the ERP to your industries? ® Yes ❑ No If no, POTW must send copy within 30 days. 27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc? ❑ Yes ® No If yes, Explain. 28. List Industries under a Schedule or Order and Type of Schedule or Order. N/A Resources 29. Please Rate the Followine: S=Satisfactory M=Marcinal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program ®S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and ®S ❑M ❑U Emergencies Access to Operable Sampling Equipment ®S ❑ M Flu Availability of Funds if Needed for Additional Sampling and/or Analysis ®S ❑M ❑U Reference Materials ®S ❑M ❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) ®S ❑M ❑U Computer Equipment (Hardware and Software) ®S ❑M ❑U NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Excel 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Surcharges, direct billing for sampling fees (via water/sewer bill). Public Perception/ Participation: 32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? ® Yes ❑ No If yes, Explain. The POTW's only SIU (Auria Albemarle, LLC) ceased the dyeing operation and SIU's flows have been significantly been reduced. 33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No If yes, Explain procedure. If no, How would the request be addressed? A request would have to be submitted in writing. The City Manager, City Attorney, Public Utilities Director, Pretreatment Coordinator and consultant would be involved with the approval process. Files would be reviewed at City Hall with City personnel in attendance. 34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential from public. If no. how would the request be addressed? A request would have to be submitted in writing. The City Manager, City Attorney, Public Utilities Director, Pretreatment Coordinator and consultant would be involved with the approval process. Confidential files would be secured in a locked file cabinet. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No 36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No 37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ®NA Permitting (Industrial Waste Survey-IWS): 38. How does the POTW become aware of new or changed Users? City's Economic Development staff would contact Public Utilities Director and/or Pretreatment Coordinator. 39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an SIU?) The Pretreatment Coordinator would evaluate the information on the IWS form (Short/Long Forms), discharge characteristics including flow volumes, NPDES POCs, SIC Codes/categorical determinations, and potential impacts to the WWTP. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ®Yes ❑No If Yes, How many are there? 1 Please list each site and how it is permitted, if applicable. POTW's landfill leachate; local permit. 41. Does the POTW accept waste by (mark if applicable) ® Truck ®Dedicated Pipe ❑ NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) The WWTP has a designated point at the WWTP for the septage haulers and unloading activities only occur during first shift (7 am — 3 pm). The septage haulers pre -pay for tickets (includes contact information) that are turned in at the WWTP following unloading activities. Manifests are maintained along with random sampling. 43. How does the POTW allocate its loading to industries? Mark all that apply ❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ❑ Other Explain Other: 44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No If yes, What parameters are over allocated? 45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.) 46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No If yes, what percentage of each parameter? 10% 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants listed on the application limited; categorical parameters; NPDES Pollutants of Concern) NPDES POCs, categorical parameters, potential impacts to WWTP and industry need. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain. New SIUs would be required to perform monthly monitoring for twelve months to determine baseline. A reduction of the monitoring frequency would be based on sampling results. Monitoring also based on categorical determinations and potential impacts to WWTP. Twice per year monitoring would be performed at a minimum. Permit Compliance: 50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No If yes, which industries? What was (will be) the outcome of the adjudication? 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting requirements, and permit conditions, as well as for SNC. SNC determinations based on Compliance Judgment Worksheet. Violations (limit, monitoring, permit condition, etc.) based on Division -approved ERP. 52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, does the POTW form include all DWQ data? ❑ Yes ❑ No 53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No If no, Explain. 54. What criteria are used to determine if a slug/spill control plan is needed? The only SIU is required to have slug/spill control plan. New SIUs would be evaluated for floor drains, secondary containment, chemical storage areas, and/or potential impacts to WWTP. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Checklist used during inspections, contact information kept current, presence of spill response equipment, adequacy of secondary containment and chemical storage practices. 56. How does the POTW decide where the sample point for an SIU should be located? Categorical — two sampling points with one being the categorical effluent and second being all combined waste streams; Non -categorical — all combined waste streams. 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: ® Yes ❑ No SIU: ❑ Yes ❑ No If yes, Explain. POTW maintains sampling SOPS and sampler manuals. Note: POTW staff collects all samples. 58. Who performs sample analysis for the POTW for Metals — Environment 1 Conventional Parameters - Environment 1 Organics — Environment 1 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. City staff uses internal COC (flow, pH, and temperature) and contracted laboratory (Environment 1) COCs. SIU will use contracted laboratory (Rogers & Callcott) COC if split sampling is performed. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA): 60a. 60b. 60c. 60d. 60e. 60f. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO If NO to any above, list violations Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: 61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No If no, Who completes your HWA? Nadine Blackwell/Consultant/SUEZ Phone: 3( 36) 766-0270 NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change ❑More LTMP data available ❑Resolve over allocation 05 year expiration ❑Other, explain. 63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality 64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? Yes ❑ No Explain. N/A - Reserve capacity in WWTP. 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW: 66. User Name 1. Auria Albemarle, LLC 2. 3. 67. IUP Number 1 0003 68. Does File Contain Current Permit? I ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 69. Permit Expiration Date 1 9/30/21 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A I N/A 71. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 72. Does File Contain Inspection Completed Within Last Calendar Year? ® Yes El No ❑Yes ❑ No El Yes El No 73. a. Does File Contain Slug/Spill Control Plan? . ®Yes ❑No R a. []Yes [:No - a. [-]Yes []Nob. If No, is One Needed? See Inspection Form from POTW . ❑Yes []No b. ❑Yes ❑No b. []Yes []No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 75. a. Does File Contain Original Permit Review Letter from Division? a. ®Yes ❑No a. []Yes []No a. ❑Yes []No b. All Issues Resolved? b.❑Yes❑No®N/A 11 b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 76. During Most Recent Semi -Annual Period, Did POTW Complete its ® Yes ❑ No ❑Yes ❑ No ❑ Yes ❑ No Sampling as Required by IUP, including Flow? 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required b IUP, includingFlow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A time? 80a. For categorical IUs 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 b IUP? 80b. For categorical IUs 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? 81. During Most Recent Semi -Annual Period, Did POTW Identify All 7MEDes❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Limits Non -Compliance from Both POTW and SIU Sam ling? 82. During Most Recent Semi -Annual Period, Did POTW Identify All ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Re ortin Non-Com liance from SIU Sampling? 83. a. Was 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 and obtain results within 30 days of becoming aware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑No®N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A 84. During Most Recent Semi -Annual Period, Was SIU in SNC? I ❑ Yes ®No 11 ❑ Yes ❑ No ❑ Yes ❑ No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NOON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NOON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 88. a. Does 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 89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑ Yes ®No ❑ Yes ❑ No ElYes El No Information For You? NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 FILE REVIEW COMMENTS: 8. The POTW reported effluent limit violations in September 2019 (TSS and fecal coliform), June 2019 (BOD, ammonia, fecal coliform, chronic toxicity), May 2019 (BOD, ammonia, fecal coliform), April 2019 (BOD, ammonia, TSS), March 2019 (TSS and ammonia), February 2019 (TSS and ammonia), January 2019 (BOD, ammonia, TSS), December 2018 (ammonia) and November 2018 (ammonia and fecal coliform). The WWTP issues attributed to these violations include the following: low influent BOD loading, inability to isolate individual aeration basins during low flow/organic loading conditions and excessive I&I. 9. The POTW has submitted an application to the Division for an SOC to address both the collection system and WWTP. The SOC is currently under Division review. 21. The POTW will need to submit a copy of the IJA (with Stanly County) to the Division's Pretreatment Unit. 72. The POTW last inspected Auria Albemarle, LLC on 12/13/18. 78. The POTW collects all samples for the SIU. INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspection type 0 N I C 10 10 12 14 12 111 1OS 19 UD (DTIA) (TYPI) 1. Industry Inspected: Auria Albemarle, LLC 2. Industry Address: 313 Bethany Road, Albemarle, NC 28001 3. Type of Industry/Product: Textile/Automotive Carpet 4. Industry Contact: Hans Peoples Title: Technical Manager Phone: (704) 983-8394 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: Inspector Facility Type 0 (INSP) (FACC) Auria Albemarle, LLC (Auria) currently performs carpet tufting and latex backing. The dyeing process ceased in September 2018 and caused a significant reduction of the flows to the POTW by approximately 90%. The facility has approximately 188 employees and operates two production shifts, sixteen hours per day five to six days per week. Auria currently produces one million yards of product per month. The facility's pretreatment system currently includes dual lint screens and continuous flow measurement. US Ecology (or a subcontracted company) has been contracted to dispose of the facility's universal waste, carpet waste, etc. Safety Kleen disposes of any used motor oil and Republic Services disposes the screenings (lint screening system). SUMMARY AND COMMENTS: The POTW's LTMP was recently revised and approved by the Division in April 2019. The June 2019 LTMP sampling event revealed the detection levels of several parameters [Bis (2-ethylheyxl) Phthlate, Cr6, Ag, As, Cd, Pb, Se] being above the LTMP's detection levels. The POTW had changed contracted labs prior to the September 2019 LTMP sampling event with only As and Se detection levels being above the LTMP's detection levels. The Pretreatment Coordinator will contact the contracted lab to address these detection levels. The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly implemented. NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 POTW Rating: Satisfactory Audit COMPLETED BY Marginal ❑ E��D/ocuSipgnedAAby: WPiY YJGGG —"96DNCC3437... Unsatisfactory ❑ TE: 11/15/2019 Wes Bell, Env. Specialist II, Mooresville Regional Office DocuSigned by: 11/15/2019 AUDIT REVIEWED BY: DATE: W. Corey Basinger, Regional Supervisor, Mooresville Regional Office NC DWR Pretreatment Audit Form Revised: December 2016 Page 7