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Home My WebLink AboutNC0025909_PA_20220104 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED January 4, 2022 Doug Barrick Email: dbarrick@rutherfordton.net Town of Rutherfordton SUBJECT: Pretreatment Audit Rutherfordton WWTP NPDES WW Permit No. NC0025909 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Rutherfordton WWTP’s Pretreatment Program on 11/24/2021. This inspection was conducted to verify that the program is being managed and maintained in compliance with all Pretreatment regulations. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Reports Ec: LF Nadine Blackwell, Pretreatment Coordinator Phillip Reynolds, ORC DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NC0025909 21/11/24 G S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Rutherfordton WWTP NC Hwy 221 Rutherfordton NC 28139 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:30AM 21/11/24 16/07/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Phillip E Reynolds/ORC/828-287-2141/ Other Facility Data 12:00PM 21/11/24 20/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Doug Barrick,129 N Main St Rutherfordton NC 28139/Town Manager/828-287-3520/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Pretreatment Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Stephanie A Williams DWR/ARO WQ/828-296-4500/ Mikal Willmer DWR/Division of Water Quality/828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 1/5/2022 1/5/2022 1/5/2022 NPDES yr/mo/day 21/11/24 Inspection Type G3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer and Stephanie Williams, with the Asheville Regional Office, conducted a Pretreatment Audit of the Town of Rutherfordton’s Pretreatment Program on November 24, 2021. This inspection was conducted in conjunction with the facilities WWTP inspection. Suez & Allied Die Casting personnel were present and assisted in the inspection. Overall, the program appears to be maintained in compliance with the guidelines of the delegated pretreatment program. The Rutherfordton Pretreatment Program only has one CIU, Aallied Die Casting. As of July 2021, Aallied is no longer discharging process wastewater to the POTW. All process wastewater is now evaporated onsite. The CIU wishes to retain the permit as a backup, should production increase or the evaporation system need to be taken offline. The CIU will continue to submit “no discharge” reports. The composite sampler and flow meter will also be maintained, so samples can be collected should discharges resume. There are currently no over allocations and all sampling is being carried out as required by the STMP. Facility files are well organized and kept onsite at the WWTP as well as retained in Suezes WIMS system. There are currently no plans to change or modify the pretreatment program at this time. NC0025909 17 (Cont.) Page#2 DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 Permit:NC0025909 Inspection Date:11/24/2021 Owner - Facility: Inspection Type: Rutherfordton WWTP Pretreatment Audit Yes No NA NE Page#3 DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Rutherfordton 2. Control Authority Representative(s): Phillip Reynolds & Nadine Blackwell 3. Title(s): ORC & Pretreatment Coordinator 4. Address of POTW: 1021 S. Main St., Rutherfordton NC 28139 Mailing: 129 N Main St. City Rutherfordton Zip Code 28139 Phone Number 828-287-2141 Fax Number E-Mail phillip.reynolds@suez.com 5. Audit Date 11/24/2021 6. Last Inspection Date: / / Inspection Type: PCI Audit NA Program reinstated in 2019 7. Has Program Completed All Requirements from the Previous Inspection and Progr am Info Sheet(s) ? Yes No NA 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 ICIS Coding Main Program Permit Number MM/DD/YY N C 0 0 2 5 9 0 9 11 24 21 10. Current Number of Significant Industrial Users (SIUs)? 1 11. Number of SIUs with No IUP, or with an 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)? 1 19. Number of CIUs in SNC? 0 DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 20. 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) 7/15/20 Yes No Yes No Industrial Waste Survey (IWS) 4/15/20 Yes No 7/01/19 Yes No 5/01/2024 Sewer Use Ordinance (SUO) 4/15/19 Yes No 7/01/19 Yes No Enforcement Response Plan (ERP) 2/13/20 Yes No 2/14/20 Yes No Long Term Monitoring Plan (LTMP) 5/15/19 Yes No 7/01/19 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. 22. If yes to #21, 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 #21, 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 04/15/2019 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 NA Resources 29. Please Rate the Following: S=Satisfactory M=Marginal 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 Emergencies S M U Suez utilizes company vehicles for employees. Access to Operable Sampling Equipment S M U Utilize a portable sampler. 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 Employees attend pretreatment conference and annual workshop when offered. Computer Equipment (Hardware and Software) S M U DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No Explain Yes or No. Suez uses HACH WIMS to manage data, which is backed up daily. Files are also retained at the WWTP in binders for both the program and the industrial user. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The Town charges the industry for sampling conducted by POTW. No surcharge rates currently used. 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. 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? Request would come through the Town and Suez or Industry would provide requested information if not listed as confidential. 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 confi dential from public. If no how would the request be addressed? If Suez determined information was considered a trade secret or proprietary information, it would be marked and filed as confidential. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatmen t? Yes No Suez regularly communicates with the industry via email and maintains a good working relationship. 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? The Town is aware of development and new industries and discusses potential impacts with Suez. Engineers will also discuss any proposed changes that may affect or impact the WWTP. 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?) It is based on whether they meet the definition of a CIU or SIU or whether new loadings would constitute > 5% MAHL. 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 Dedicated Pipe NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) NA 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.) NA 46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No If yes, what percentage of each parameter % Currently only one industrial user that is no longer discharging to POTW. 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes No If yes, Explain. DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 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) Categorical limits, local limits and 5% MAHL. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Frequency is based on potential to impact facility. To obtain a baseline , Suez will typically require sampling at least once every six months. 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. The POTW judges compliance based on ERP and SNC regulatory definitions. 52. Does the POTW use the Division’s model inspection form or equivalent? Yes No If no, does the POTW form include all Division data? Yes No 53. Were all SIUs evaluated for the need of a slug/spill contr ol 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 potential for discharge to the collection system during a spill. Suez also utilizes a standard checklist. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Based on a standardized checklist for all industries. This ensures the plan includes key requirements such as spill control procedures and notification. 56. How does the POTW decide where the sample point for an SIU should be located? It is based on the most representative location and a point where process wastewater can be isolated from other waste streams. Suez attempts to avoid combined waste streams. 57. Has the POTW established a procedure to ensure that representative samples will b e 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. They use flow proportional sampling, helped industry place, and set up sampler. They also have the flow meter calibrated when Rutherfordton’s are calibrated annually. 58. Who performs sample analysis for the POTW for Metals Environmental 1 Conventional Parameters Environmental 1 Organics Environmental 1 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Samples are collected and sent via courier to environmental 1. Chains of Custody are retained and accompany all samples. Chains of Custody were available for review. 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? 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 Division Inspector, verify yourself! 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? Phone ( ) -- 62. Do you have plans to revise your HWA in the near future? Yes No DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 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 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 d isposal)? Yes No Explain. N/A, no current issues; however, the Town continues to look for new fields to add to their RLAP permit WQ0032855. Additionally, the Town contracts with US Biosolids to land apply residuals under their RLAP Permit WQ0037135. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No significant changes planned. CIU is now recycling and evaporating process wastewater. DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Aallied Die Cast 2. 3. 67. IUP Number 0003 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 12/31/23 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 464.14 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 72. Does File Contain Inspection Completed Within Last Calendar Year? Yes No Yes No 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 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? Yes No N/A Yes No N/A Yes No N/A 075. 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? Yes No Yes No Yes No 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 Sampling as Required by IUP, including Flow? Yes No N/A Yes No N/A Yes No N/A 79. During Most Recent Semi-Annual Period, Did SIU submit all reports on time? Yes No N/A Yes No N/A Yes No N/A 80a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? Yes No N/A Yes No N/A Yes No N/A 80b. For categorical IUs with Production based limit s, does file include production rates and/or flows as Required by IUP? Yes No N/A Yes No N/A Yes No N/A 81. During Most Recent Semi-Annual Period, Did POTW Identify All Limits Non-Compliance from Both POTW and SIU Sampling? Yes No N/A Yes No Yes No 82. During Most Recent Semi-Annual Period, Did POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/A Yes No N/A Yes No N/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 No Yes No Yes No 85. During Most Recent Semi-Annual Period, Was Enforcement Taken as Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? Yes No N/A Yes No N/A Yes No N/A 86. Does File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A 87. Does File Contain Proof Of Penalty Collection? Yes No N/A Yes No N/A Yes No N/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 No Yes No Yes No FILE REVIEW COMMENTS: Data is maintained in Suez’s Hach WIMS and backed up daily. Aallied Die Casting stopped discharging in July 2021. All process wastewater is now recycled/evaporated onsite. Will retain permit and submit “no discharge” reports. Industry inspection was planned for the week of November 29th. 74. Facility has a TTO; however, they are now using the alternative monitoring allowed for 464.14 CIU s and monitoring for O&G. 80a. Facility divided their waste stream to avoid dilution and need for the CWF. When Aallied is not using their evaporator, all facility industrial process wastewater is discharged separately from the domestic wastewater onsite. DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 7 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY N C 0 0 2 5 9 0 9 11 24 21 1. Industry Inspected: Aallied Die Cast 2. Industry Address: 401 Aallied Dr. Rutherfordton, NC 3. Type of Industry/Product: Metal Die Casting 4. Industry Contact: Jeff Jackson Title: Manufacturing Manager Phone: (828) 286-4003 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: Suez did not perform their Annual Inspection on the day of our industry site visit (scheduled for following week); however, we discussed all aspects with Aallied Die Casting regarding spill control, industrial processes, sampling location, procedures, and current process wastewater disposal onsite. Facility currently utilizes an evaporator and is no longer discharging to the POTW. All oil and debris are captured and contained in a tank outside of the building which is in secondary containment and hauled off as needed. Floor drains are installed throughout the facility. All drains send process wastewater to the onsite treatment system. Facility maintains an Air Permit and Stormwater Permit. Building’s cargo door appeared to be bermed and sloped back towards the interior. The autosampler is maintained outside within a shed. Flow meter is calibrated annually by Delta when Rutherfordton’s meters are calibrated. Any spills would go through their pretreatment process before being discharged to the POTW. Audit SUMMARY AND COMMENTS: Audit Comments: Overall the Pretreatment program is being well managed and maintained. Rutherfordton’s one CIU is evaporating all process wastewater. The last process wastewater discharge d to the collection system was in July of 2021. Aallied Die Casting wishes to retain the permit, should they need to discharge in the future. Rutherfordton is still waiting on final Division approval for the most recently submitted HWA. Submitted HWA was available for review. Requirements: Recommendations: Requested the POTW continue to maintain a record of the “no discharge” monitoring reports for the industry and maintain the current open communication with the industry regarding operations and maintenance of the onsite flow meter and autosampler. 31. Recommended the Town consider surcharge rates, or another means to recoup industry costs should additional users connect on to the system. DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56 NC DWR Pretreatment Audit Form Revised: December 2016 Page 8 NOD: Yes No NOV: Yes No QNCR: Yes No POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: Mikal Willmer & Stephanie Williams DATE: 11/24/2021 Mikal Willmer & Stephanie Williams, Asheville Regional Office DocuSign Envelope ID: F20C0DDC-CAB4-46DD-AA8E-47DF406BFA56