The URL can be used to link to this page

Home My WebLink AboutNC0025984_PA_20220106 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED January 06, 2022 Janet Mason Email: janetmason@townofforestcity.com Town of Forest City SUBJECT: Pretreatment Audit Forest City WWTP NPDES WW Permit No. NC0025984 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an Pretreatment Audit of the Town of Forest City Pretreatment Program on 12/07/2021. This Audit 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 Report & PA Ec: LF Tommy Wilson, Pretreatment Coordinator Jacob Hodge, ORC Sonny Penson, Superintendent DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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 NC0025984 21/12/07 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) Forest City WWTP 397 Riverside Dr Forest City NC 28043 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:00AM 21/12/07 21/12/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jacob William Hodge/ORC/828-248-5217/ Thomas Paul Wilson/ORC/828-248-5217/ Other Facility Data 12:30PM 21/12/07 26/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Sonny Penson,PO Box 728 Forest City NC 280430728//828-248-5217/8282474626 Contacted Yes 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 Lauren E Armeni DWR/ARO WQ/828-296-4500/ 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: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 1/6/2022 1/6/2022 1/6/2022 1/6/2022 NPDES yr/mo/day 21/12/07 Inspection Type G3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer, Stephanie Williams, and Lauren Armeni, with the Asheville Regional Office, conducted an Audit of Forest City’s Pretreatment Program on December 7, 2021, with follow-up questions on January 5, 2022. This audit was conducted to determine whether the program is being maintained in compliance with all pretreatment regulations. Jacob Hodge and Tommy Wilson with the Town of Forest City and Jeffrey Childers with Everest Textile were present and assisted in the inspection. Overall, the program is being maintained in compliance. The Town of Forest City’s pretreatment program covers two separate WWTPs. Staff report there are no impacts to the Forest City WWTP from the industrial discharges into the system. The Town has adequate capacity and, if needed, could lower allocations given to the current industries. The Riverstone WWTP continues to have issues with metals concentrations of their sludge. This has been attributed to the domestic discharge from one of their industries. This has not caused an exceedance of effluent limits; however, the sludge has exceeded the ceiling concentration limits for land application and must be hauled to the landfill. The Town has been working for the past couple years to bring the facility in compliance with their IUP and they are currently working on a consent order to resolve the ongoing issue. The paperwork review and the annual industry inspection of Everest Textile was conducted, which included a tour of the facility and all chemical storage. Division staff had some concern with secondary containment for bulk chemical storage throughout areas of the facility due to the potential discharge to storm drains and surface waters. Please continue to keep the Division apprised of any concerns. Any continued issues/concerns can be brought to the attention of the appropriate Division as necessary. NC0025984 17 (Cont.) Page#2 DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 Permit:NC0025984 Inspection Date:12/07/2021 Owner - Facility: Inspection Type: Forest City WWTP Pretreatment Audit Yes No NA NE Page#3 DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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: Town of Forest City 2. Control Authority Representative(s): Jacob Hodge, Tommy Wilson and Sonny Penson 3. Title(s): Pretreatment Coordinator-Tommy Wilson, Jacob Hodge-ORC & Sonny Penson-Superintendent. 4. Address of POTW: Mailing PO Box 728 City Forest City- Zip Code 28043 - Phone Number 828-248-5217 Fax Number 828-247-1626 E-Mail jacobhodge@townofforestcity.com or tommywilson@townofforestcity.com 5. Audit Date 12/07/2021 6. Last Inspection Date: 05/01/2019 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. No compliance issues to date; however, metals concentrations are becoming a concern again from AZP discharge. The Riverstone Plant currently has AEO haul sludge due to metals. Typically, the sludge is hauled to the FC WWTP. 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 8 4 12 07 21 10. Current Number of Significant Industrial Users (SIUs)? 5 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? 3 15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? 1 16. Number of SIUs in SNC with Pretreatment Schedule? 0 17. Number of SIUs on Schedules? 1 18. Current Number of Categorical Industrial Users (CIUs)? 2 19. Number of CIUs in SNC? 1 DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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) RS 1/24/18 FC8/16/18 Yes No RS 2/8/18 FC 8/17/18 Yes No RS 12/31/22 FC 3/1/24 Industrial Waste Survey (IWS) 8/31/18 Yes No 10/05/18 Yes No RS/FC 9/1/23 Sewer Use Ordinance (SUO) 2/22/13 Yes No 2/25/13 Yes No Enforcement Response Plan (ERP) 10/28/19 Yes No 2/5/20 Yes No Long Term Monitoring Plan (LTMP) RS 10/28/14 FC 8/24/18 Yes No RS 12/29/14 FC 8/29/18 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. Ellenboro 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. Have agreement with Ellenboro to provide cleaning and oversite of collection system; however, Ellenboro is financially responsible for all repairs and upgrades to system. 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 2/18/2013 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. AZP adjudicated metals limits and AO. 28. List Industries under a Schedule or Order and Type of Schedule or Order American Zinc Products- MOU. 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 Access to Operable Sampling Equipment S M U Availability of Funds if Needed for Additional Sampling and/or Analysis S M U Can be adjusted as needed Reference Materials S M U Everything available online Staff Training (i.e. Annual and Regional Workshops, Etc.) S M U Available as needed DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 Computer Equipment (Hardware and Software) S M U 30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No Explain Yes or No. House data electronically in excel and maintain hard copies in binders onsite. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. 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. 33. Has anyone from the public ever requested to review pretreatment program files? Yes No If yes, Explain procedure. If no, how would the request be addressed? The Town would either provide electronic copies of requested information or allow the public to review in person. 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 proce dure for keeping files confidential from public. If no how would the request be addressed? Industry would notify Town of any proprietary items. The Town would not let the public see the information that the industry asks to remain confidential. 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 Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? EDC for new users and Industry for changed users 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 the pretreatment application, sampling and whether users change their process. 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) Trucks dump at septic station and waste is screened. 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 ? RS 33% FC 50% 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes No If yes, Explain. Yes, AZP requested all metals allocation. DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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) When sampling any POCs that have hits, a limit is assessed. All categorical parameters are followed. Monitor only for any other pollutants received. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. 1/6 months unless it is a new industry then it would be 1/month. 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? AZP. An agreed upon consent order to meet metals and ammonia limits whether through installation of pretreatment or moving to treating their own waste. 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporti ng requirements, and permit conditions, as well as for SNC. Compliance is judged on a case-by-case basis based on history of industry and potential to adversely impact the plants. 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 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 potential for spills to enter the discharge to the POTW. The POTW requires all industries to maintain a spill control plan, even if there is minimal risk of discharge to the collection system. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Points of contact and adequate containment ability. 56. How does the POTW decide where the sample point for an SIU should be located? Last point of contact before domestic is entered into sewer (if po ssible). 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each ti me? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: Yes No SIU: Yes No If yes, Explain. POTW has industry explain their sampling techniques and occasionally monitors their sample collection. 58. Who performs sample analysis for the POTW for Metals ETS Conventional Parameters ETS Organics ETS 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Carefully label bottles and make sure the CoC matches all samples collected. Whoever samples releases CoC to carrier/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? 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 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 DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 Explain. 63. In general, what is the most limiting criteria of your HWA? Inhibition Pass Through Sludge Quality (RS) No limiting issues for Forest City WWTP due to capacity. 64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? Yes No Explain. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? None currently. DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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. American Zinc 2. Everest Textile 3. West Rock 67. IUP Number 008 009 005 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 2/28/25 2/28/25 2/28/23 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A N/A 433 & 463 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 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? 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 limits, 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 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: Staff report they have not had issues with industries reporting data within the required time frame. All penalty collections are handled from town hall. AZP recently had an outstanding balance for unpaid penalties. All facilities are required by the POTW to have a spill control plan regardless of potential impact the collection system. West Rock’s TOMP was updated in 2018. DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 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 8 4 12 07 21 1. Industry Inspected: Everest Textile 2. Industry Address: 1331 W. Main St. Forest City, NC 28043 3. Type of Industry/Product: Textiles 4. Industry Contact: Jeffrey Childers Title: EHS Manager Phone: ( 828) 245-6755 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: The POTW had the industry representative take us through the entire facility. We observed all drains and chemical storage onsite. The POTW pointed out areas of concern and areas that have caused issues in the past. It was noted that chemicals are stored on the second floor and piped overhead throughout the facility. There were concerns with exterior chemical storage within secondary containment and the proximity to surface water and discharges to storm drains. These concerns were conveyed to the industry; however, this is outside the scope of their Pretreatment Audit and pertains to their active stormwater permit. It appears the original O&G issues have been resolved with the DAF installation. All process wastewater is routed through an open-air holding pond before being discharged to the POTW. Everest staff should closely monitor this pond to ensure foreign debris do not enter the collection system. This was an item of note in the POTWs annual industry inspection conducted in 2020. Audit SUMMARY AND COMMENTS: Audit Comments: Overall, the program is being well maintained. Forest City has actively implemented their SUO and ERP over the past several years and worked closely with several industries to return them to permit compliance. All paperwork was readily available for review and maintained onsite at the Forest City WWTP. There have been no reported impacts to the Forest City WWTP due to industrial discharge. The Riverstone facility continues to have metals issues from one the industrial users. The Town is currently working with this industry to finalize a consent order that will contain compliance milestones. Requirements: Riverstone’s HWA is due at the end of 2022. Recommendations: Continue to keep the Division apprised of any industry concerns or potential impacts to the system. Additionally, should the POTW have any concerns with an industry’s secondary containment or practices onsite that may impact stormwater, surface waters or air quality, that are outside the scope of the pretreatment program, please contact the Division for follow-up. NOD: Yes No NOV: Yes No QNCR: Yes No DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671 NC DWR Pretreatment Audit Form Revised: December 2016 Page 8 POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: Mikal Willmer, Lauren Armeni, and Stephanie Williams DATE: 12/7/2021 Asheville Regional Office DocuSign Envelope ID: CB00395A-E6E1-42B3-BA7F-CEFD2EECC671