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HomeMy WebLinkAboutNC0025496_Inspection_20211221ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director Robert Pearson, Public Utilities Director City of Lincolnton Post Office Box 617 Lincolnton, NC 28093 Dear Mr. Pearson: NORTH CAROLINA Environmental Quality December 21, 2021 SUBJECT: Pretreatment Compliance Inspection City of Lincolnton NPDES Permit No. NC0025496 Lincoln County Enclosed is a copy of the Pretreatment Compliance Inspection report for the inspection of the City of Lincolnton's approved Industrial Pretreatment Program on December 21, 2021, by Mr. Wes Bell of this Office. Please advise the Pretreatment staff of our findings by forwarding a copy of the enclosed report. 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 via email at wes.bell@ncdenr.gov. Enclosure: Inspection Report NORTH CPPOLINA OE Sincerely, ,-DocuSigned by: A*•144w H Pam► fo r F161 FB69A2D84A3... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 I Mooresville. North Carolina 28115 704.663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION1 1. Control Authority (POTW) Name: City of Lincolnton 2. Control Authority Representative(s): Daniel Perry 3. Title(s): Pretreatment Program Coordinator 4. Last Inspection Date: 9/5/19 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 NC0025496 MM/DD/YY 12/21/21 7. Current Number Of Significant Industrial Users (SIUs)? 5 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)? 3 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 either of the Last 2 Semi -Annual Periods? Not Been Published for Public Notice?(May refer to PAR if Excessive SIUs in SNC) SNC for SNC for Not Pul 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? /1YES NO /1 YES ❑ NO See Comments Section. Limits: None Reporting: None )lished: N/A N/A ❑ YES aO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES 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 ❑ 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) 5/8/17 /1 Yes ❑ No 8/3/17 a Yes ❑ No 6/1/22 Industrial Waste Survey (IWS) 9/30/19 /1 Yes ❑ No 1/17/20 /1 Yes ❑ No 10/1/24 Sewer Use Ordinance (SUO) 10/2/13 /1 Yes ❑ No 10/7/13 /1 Yes ❑ No Enforcement Response Plan (ERP) 12/6/19 a Yes ❑ No 2/5/20 0 Yes ❑ No Long Term Monitoring Plan (LTMP) 8/24/21 a Yes ❑ No 12/1/21 /1 Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 29. User Name 1. Cataler NA 2. Cosette Pharmaceuticals 3. FMS Enterprises USA 30. IUP Number 0021 0012 0027 31. Does File Contain Current Permit? /1 Yes ❑ No /1 Yes ❑ No /1 Yes ❑ No 32. Permit Expiration Date 6/30/23 6/30/24 4/30/23 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A 439 N/A 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? /1 Yes ❑ No /1 Yes ❑ No a Yes ❑ No 35. Does File Contain an Inspection Completed Within Last Calendar Year? A Yes ❑ No /1 Yes ❑ No A Yes ❑ No 36. a. Does the File Contain a 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 1No b. •Yes VNo 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 38. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. ► Yes •No I b.❑Yes❑NoEN/AJ a. ► Yes ■No b.❑Yes❑NoEN/A a. 1Yes •No b.❑Yes❑NoEN/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? A Yes ❑ No /1 Yes ❑ No A Yes ❑ No 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? /1 Yes ❑ NqJ /1 Yes ❑ No I Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP, including flow? ® Yes ❑No❑N/A ® Yes ❑No❑N/A ®Yes❑No❑N/A 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports on time? ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? ❑Yes ONO EN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? ❑ Yes ❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? ■ Yes •NoLNA ❑Yes❑NoEN/A ❑Yes❑NoEN/A 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? a.❑Yes❑NoEN/A b.❑Yes❑NoEN/A c.❑Yes❑NoDN/A a.❑Yes ❑NoEN/A b.❑Yes❑NoEN/A c.❑Yes❑No®N/A a.❑Yes ❑NoEN/A b.❑Yes ❑NoEN/A c.❑Yes ❑NoDN/A c. Did POTW resample within 30 days of knowledge of SIU limit violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes /1 No ❑ Yes r No ❑ Yes I No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes ONO EN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 49. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? a.❑Yes❑NoEN/A b.❑Yes❑NoEN/A a.❑Yes❑NoEN/A b.❑Yes ❑NoEN/A a.❑Yes ❑NoEN/A b.❑Yes❑NoEN/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ❑ Yes /1 No ❑ Yes L No ❑ Yes /1 No NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: 17. Effluent total suspended solids violations were reported in February 2020 (weekly average) and March 2021 (weekly and monthly average). Weekly average effluent BOD violations were reported in February 2021 and March 2021. A monthly average effluent Bis (2-ethylhexyl) Phthalate was reported in September 2021. 18. A SIU's IUP (Celadon Recycling Solutions) was terminated in August 2020. The industry's actions including the refusal of Pretreatment staff access to the site and the severing of the discharge line to the POTW were contributing factors to the IUP termination. 35. SIU inspections were performed on 11/17/21 (Cataler NA), 12/9/21 (Cosette Pharmaceuticals) and 12/3/21 (FMS Enterprises). 39. POTW contracts with Statesville Analytical, Pace Analytical Services and Two Rivers Utilities for LTMP and IUP analyses. Note: Blue Ridge Labs was previously used; however, the lab will no longer be performing water/wastewater analyses. 41a. Cataler NA, Cosette Parmaceuticals and FMS Enterprise had contracted Blue Ridge Labs for IUP analyses. SUMMARY AND COMMENTS: The Pretreatment staff must ensure that the correct detection level (ex. PQL) is used for all future compliance determinations and reporting (LTMP and/or IUP). 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 POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ PC1 COMPLETED BY: PCI REVIEWED BY: DocuSigned by: 100(4,8 AC1606DOOCC3437... DATE: 12/21/2021 Wes Bell, Environmental Specialist II, MRO/WQROS, NC DEQ ,-DocuSigned by: A4,41e4ii H P;zti.t' fo r F161 FB69A2D84A3... DATE: 12.21.2021 W. Corey Basinger, Regional Supervisor, MRO/WQROS, NC DEQ NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3