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HomeMy WebLinkAboutNC0023965_PCI revision_20200828DocuSign Envelope ID: E91AC7F9-8B95-4D8E-A403-14787EA32227 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources en rnL ounu F r BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Cape Fear Public Utility Authority 2. Control Authority Representative(s): William Roy, Maggie Butler, Brock Ridout 3. Title(s): Envir. Compliance Manager, Envir. Compliance Supervisor, Envir. Compliance Officer 4. Last Inspection Date: 09/12/18 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: ICIS CODING Main Program Permit Number lull//�1�1 Are Milestone Dates Being Met? ❑ YES ❑ NO 7. Current Number Of Significant Industrial Users (SIUs)? 6 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 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: 0 Reporting: 0 dished: 0 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 Division Inspector, please verify yourself! 26. 27. IfNO to 23 - 26, list violations Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? If yes, which ones? Eliminated: Added: NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 DocuSign Envelope ID: E91AC7F9-8B95-4D8E-A403-14787EA32227 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) 05/25/17 06/27/19 ® Yes ❑ No 08/17/17 08/07/19 ® Yes ❑ No 05/31/22 06/30/24 Industrial Waste Survey (IWS) 07/18/18 ® Yes ❑ No 07/31/18 ® Yes ❑ No 08/01/23 Sewer Use Ordinance (SUO) 12/29/16 ® Yes ❑ No 03/21/17 ® Yes ❑ No Enforcement Response Plan (ERP) 11/07/19 ® Yes ❑ No 02/05/20 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 12/07/17 ® Yes ❑ No 12/12/17 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. New Hanover County Hospital 11 2. Waste Management 3. SR&R 30. IUP Number S143 N2013A N2012A 31. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ No I ® Yes ❑ No 32. Permit Expiration Date 1 06/30/25 06/30/25 11 06/30/25 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A N/A N/A 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? I ❑ Yes ®No ® Yes ❑ No I ❑ Yes ® No 36. a. Does the File Contain a Slug/Spill Control Plan? a. ®Yes ❑No a. ❑Yes ENo a. ❑Yes ENo b. If No, is One Needed? (See Inspection Form from POTW) b. El es ❑No b. ❑Yes ENo b. ❑Yes ENo 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑Nol N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes ❑No a. EYes ❑No a. EYes ❑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 9770 ❑ 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 lUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A production rates and/or flows as Required b 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❑NoEN/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. If applicable, Did POTW resample within 30 days of becoming aware of SIU limit violations in the POTW's sampling of the SIU? e.❑Yes❑No®N/A e.❑Yes❑No®N/A e.❑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❑NoEN/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❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No[D ❑Yes❑NoEN/A ❑Yes❑NoON/A 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 ® Requested Information For You? !I=es NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 DocuSign Envelope ID: E91AC7F9-8B95-4D8E-A403-14787EA32227 No FILE REVIEW COMMENTS: S143-New Hanover County Hospital • 935- Covid19 restrictions have prevented an on -site inspection so far in 2020 • 936- Slug/Spill plans are reviewed as part of the inspection process by CFPUA staff • 938- IUP Permit was approved by NCDEQ on April 17, 2020 • 939- Sampling by the POTW was conducted on 04/04/19, 11/13/19 and is scheduled for September 2020 • #40- COC were included in the files, sample analysis is performed by CFPUA and by Pace Analytical Labs • 941- SIU sampling is performed by Envirochem and includes flow volumes • 943a- In March 2020 the flowmeter failed and no flow was available for 8-9 day period, however total flow for the month could be calculated • 944- The SIU notified the POTW of flowmeter failure via email • 947- A Notice ofDeficiency (NOD) was issued to S143 for failure to report flows N2013A-Waste Management • 934- Permit application submitted on 03/26/2020 • 935- Last inspection conducted on 03/13/20, additional inspection planned for September 2020 • 936- Slug/Spill Control Plan not required as wastewater is hauled via tanker truck • 940- COC's were included in file, analysis performed by CFPUA, Pace Analytics and GEL Labs • #41- Monthly reports are submitted by the SIU for hauling activities conducted N2012A-SR&R • #34- Permit application submitted on 01/02/20 • #35- Last site inspection conducted on 03/27/19, due to COVID19lockdown site inspections could not be performed, a tentative site inspection is planned for September 2020 • 936- Waste is hauled to POTW so Slug/Spill Control Plan is not required • 938- IUP Permit was approved by NCDEQ on 04/17/20 • #39- Analysis of hauled wastewater is reported to the POTW each month • #40- Analysis of POTW samples is performed by CFPUA, Pace Analytics and GEL Labs • 943a- In February, March and April indicated violations for BOD and O-Cresol, also in these month violations occurred for incorrect detection limits. The nature of the wastewater can cause interference in the analysis • 947- A Notice of Violation is being processed for the sampling exccedances of Feb, Mar, Apr, 2020 3. Type of la"stFy,44odoeti NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 DocuSign Envelope ID: E91AC7F9-8B95-4D8E-A403-14787EA32227 OVERALL SUMMARY AND COMMENTS: Comments: The Cape Fear Public Utility Authority continues to manage a very effective pretreatment program. All files referencing program elements are well organized and complete. Requirements: Recommendations: NOD: ❑ YES ®NO NOV: ❑ YES ®NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory Marginal Unsatisfactory PCI COMPLETED BYL7F141E73B6F DocuSigned by: _n��sgnad tiY�; DATE: 1/21/2021 PCI Revision 3456_. NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4