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HomeMy WebLinkAboutNC0032077_Pretreatment Audit_20210512ATA NCDENR EN,RONME, n.o RE=o ,CE= NORTH CAROLINA DIVISION OF WATER QUALITY PRETREATMENT AUDIT REPORT Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Contentnea Metropolitan Sewerage District 2. Control Authority Representative(s): Renee Smith 3. Title(s): Pretreatment Coordinator 4. Address of POTW: 900 Wiley Gaskins Road Mailing PO Box 477 City Grifton Zip Code 28530 Phone Number 252-524-5584 Fax Number E-Mail crosd300@embargmail.com 5. Audit Date 5/11/2021 6. Last Inspection Date: 6/30/2020 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. 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 PCS (WENDB)Coding Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type LNJ INICIO 10 13 12 10 17 17 I I5 11 121 IGI IS I 1 (DTIA) (TYPI) (INSP) (FACC) 10. Current Number of Significant Industrial Users (SIUS)? 11. Current Number of Categorical Industrial Users (CIUS)? 12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 14. Enter Higher Number of 12 or 13 15. Number of SIUs with No IUP, or with an Expired IUP 16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods 18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods 19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 Semi -Annual Periods 3 1 0 0 0 0 0 0 0 0 SIUS CIUS NOIN NOCM PSNC MSNC SNPS 20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled 0 SNIN NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 1 21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element in their File, complete with all supporting documents and 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) 9/28/2020 /1 Yes ❑ No ❑ Yes ❑ No Industrial Waste Survey (IWS) 9/29/2020 /1 Yes ❑ No 1/26/2021 /1 Yes ❑ No 1/26/2026 Sewer Use Ordinance (SUO) 12/17/2012 @ Yes ❑ No 1/4/2013 @ Yes ❑ No Enforcement Response Plan (ERP) 3/2/2020 II Yes ❑ No 3/17/2020 II Yes ❑ No Long Term Monitoring Plan (LTMP) 1/15/2015 /1 Yes ❑ No 2/5/2015 /1 Yes ❑ No Legal Authority (Sewer Use Ordinance-SUO) 22. 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. Grifton, Ayden and Winterville make up CMSD 23. 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. CMSD was formed by the General Assembly 24. If yes to #22, Have you had any trouble working with these towns or districts? E Yes ® No El NA If yes, Explain. 25. Date of Last SUO Adoption by Local Council 1/23/2013 26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 27. Did you send a copy of the ERP to your industries? ® Yes ❑ No If no, POTW must send copy within 30 days. A copy of the Enforcement Response Plan is sent to SIU's with permit renewal 28. 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. 29. List Industries under a Schedule or Order and Type of Schedule or Order None Resources 30. Please Rate the Following: S=Satisfacto M=Marginal U=Unsatisfacto Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and Emergencies S ❑M ❑U /1 Access to Operable Sampling Equipment S ❑ M ❑ U /1 Availability of Funds if Needed for Additional Sampling and/or Analysis S ❑M ❑U ' Reference Materials S ❑M ❑U 0 Staff Training (i.e. Annual and Regional Workshops, Etc.) S ❑M ❑U Computer Equipment (Hardware and Software) S ❑M ❑U @ 31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 2 Explain Yes or No. All data is maintained in Excel files and Word documents 32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Annual permit fees Public Perception/ Participation 33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? ❑ Yes ® No If yes, Explain. 34. 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? They would be given access to the pretreatment files and analysis data 35. 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? CMSD would consult pretreatment rules, NCDENR-DWQ and Wooten Company to determine if any information qualifies for confidential status 36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No To discuss any upcoming changes or violations 37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No 38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No NA No industry in SNC in 2020 Permitting (Industrial Waste Survey-IWS) 39a...How does the POTW become aware of new or changed Users? The municipalities will notify CMSD of any new commercial/industrial users. New users are required to pay an Impact fee 39b. 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 user is required to submit the IWS (short or long depending on information provided) 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ❑Yes ®No If Yes, How many are there? Please list each site and how it is permitted, if applicable. 41. Does the POTW accept waste by (mark if applicable) ❑ Truck DDedicated Pipe ® NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) 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 % No official %. CMSD will not over allocate a pollutant 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No If yes, Explain. 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) Limits and pollutants based on IWS. A effluent scan will be analyzed along with any other potential pollutants listed in IWS. CMSD will modify any permit limits or pollutants in a modified permit based on analysis. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Monitoring frequency is based on potential harm to POTW, pollutant scans and historical data. Permit Compliance 50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 3 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. POTW completes all sampling. Permit conditions are evaluated during annual inspections. PERCS compliance judgement worksheet is used for limit violations 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? All SIU's are required to have a slug/spill control plan 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Evaluate the area to see where floor drains go 56. How does the POTW decide where the sample point for an SIU should be located? Evaluate where waste streams are located and determine a central point to collect samples representative of discharge 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. Proper training of sample personnel, ensure clean sampling equipment is used. 58. Who performs sample analysis for the POTW for Metals Environment 1 Conventional Parameters CMSD/Environment 1 Organics Environment 1 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Sample collector completes chain of custody -all samples received in CMSD lab (preservation verified) -samples for commercial lab are stored in CMSD refrigerator until transported to commercial lab Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA) 60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? Z YES ❑ NO 60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO 60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO October 2020 DMR verified 60e. If NO to any above, list violations 60f. 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? Wooten Company Miles Galloway Phone (252)757-1096 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 EINPDES limits change ❑More LTMP data available ❑Resolve over allocation ❑5 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. A plant upgrade would be required Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 4 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION 66. User Name 1. Carolina Classics Catfish 2. Winterville Machine Works 3. Weyerhaeuser Company 67. IUP Number 1114 1111 1115 68. Does File Contain Current Permit? 0 Yes ❑ No 0 Yes ❑ No LI Yes ❑ No 69. Permit Expiration Date 9/30/2021 9/30/2021 9/30/2021 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A NA 413 NA 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? 0 Yes ❑ No /1 Yes ❑ No V Yes ❑ No 72. Does File Contain Inspection Completed Within Last Calendar Year? /1 Yes ❑ No X1 Yes ❑ No i1 Yes ❑ No 73. a. Does File Contain Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) a. ®Yes ❑No b. ❑Yes No a. ®Yes No b. ❑Yes ❑No a. ®Yes ❑No b. ❑Yes No Certification, Does File Contain a Toxic (TOMP)? ❑Yes❑No®N/A r®Yes ❑No❑N/A ❑Yes❑No®N/A 74. For 40 CFR 413 and 433 TTO Organic Management Plan 75. a. Does File Contain Original Permit Review Letter from Division? b. All Issues Resolved? a. ®Yes ❑No b.❑Yes❑No®N/A a. ®Yes No b.❑Yes❑No®N/A a. ®Yes ❑No b.❑Yes❑No®N/A 76. During Most Recent Semi -Annual Period, Did POTW Complete its Sampling as Required by IUP, including Flow? 0 Yes ❑ No // Yes ❑ No V Yes ❑ No 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? 0 Yes ❑ No Yes ❑ No LI Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its Sampling as Required by IUP, including Flow? ❑Yes❑NoON/A ❑ Yes ❑NoON/A ❑Yes❑NoON/A 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on time? ❑Yes❑NoON/A ❑Yes❑NoON/A ❑Yes❑NoON/A 80a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? ❑Yes❑NoON/A ❑Yes❑NOON/A ❑Yes❑NoON/A 80b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? ❑Yes❑NoON/A ❑ Yes ❑NOON/A ❑Yes❑NoON/A 81. During Most Recent Semi -Annual Period, Did POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? ❑ Yes ❑ No NA ❑ Yes ❑ No NA ❑ Yes ❑ No NA 82. During Most Recent Semi -Annual Period, Did POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑Yes❑NoON/A ❑Yes❑NoON/A ❑Yes❑NoON/A 83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resample and submit results to POTW within 30 Days? 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? a.❑Yes ❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A 84. During Most Recent Semi -Annual Period, Was SIU in SNC? ❑ Yes /1 No 1 ❑ Yes 1 No ❑ Yes V No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? ❑Yes❑NoON/A ❑ Yes ❑No0N/A ❑Yes❑NoON/A 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoON/A ❑ Yes ❑NoON/A ❑Yes❑NoON/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A ❑Yes❑No®N/A ❑Yes❑NoNN/A 88. a. Does File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? a.❑Yes❑No®N/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested Information For You? ❑ Yes LI No ❑ Yes A No ❑ Yes LI No FILE REVIEW COMMENTS: POTW completes all sampling. SIU's are not required to sample All SIU's permits expire on 9-30-2021 NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 5 INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspec .Type Inspector Fac. Type INICI0 10 13 12 10 I7 I7 1 15 I11I21 1 IU I IS I I2 I (DTIA) (TYPI) (INSP) (FACC) 1. Industry Inspected: Weyerhaeuser Company 2. Industry Address: 371 East Hanrahan Road 3. Type of Industry/Product: Lumber Mill 4. Industry Contact: Jack Godwin Title: Environmental Manager Phone: 252-746-7217 Fax: 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: Audit SUMMARY AND COMMENTS: Audit Comments: File were organized and readily available. Requirements: Recommendations: NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory ® Marginal ❑ Audit COMPLETED BY: /65664:2- SG1142I Unsatisfactory ❑ DATE: 5/12/2021 CMSD, PERCS, and WaRO Regional Office NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 6