The URL can be used to link to this page

Home My WebLink AboutNC0020664_PA_20220620 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED June 20, 2022 Guy O'Connor, ORC Email: goconnor@spindalenc.net Town of Spindale SUBJECT: Pretreatment Audit Spindale WWTP NPDES WW Permit No. NC0020664 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted a Pretreatment Audit of the Town of Spindale’s Pretreatment Program on 5/17/2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0020664. 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 & Audit Ec: LF DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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 NC0020664 22/05/17 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) Spindale WWTP Ecology St Spindale NC 28160 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 22/05/17 20/07/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Guy Peter O'Connor/ORC/704-434-2261/ Sibyl Canipe Brotherton/ORC// Other Facility Data 12:30PM 22/05/17 24/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Guy O'Connor,327 Ecology St Spindale NC 28160//828-286-3407/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 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: C2CC5442-0472-4874-8016-2ED3EAD11B3A 6/20/2022 6/20/2022 NPDES yr/mo/day 22/05/17 Inspection Type G3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer, with the Asheville Regional Office, conducted an Audit of the Town of Spindale’s Pretreatment Program on May 17, 2022. This Audit was conducted to determine whether the Town is maintaining and enforcing their pretreatment program as required by State and Federal regulations. Guy O’Connor and Sibyl Brotherton (Spindale) were present and assisted in the inspection. Overall, the program is being maintained in compliance. Staff report there have been no adverse impacts from the industrial discharges into the system. The Town has adjusted operations at the WWTP to accommodate the change in waste stream due to reduced flows from the industries. Spindale completed their own headworks analysis (HWA) and are awaiting final approval from the pretreatment unit. Allocations: An overallocation for silver was noted during the annual report review and was discussed during the inspection. Town staff indicated the industry does not need the current allocation and will adjust limits accordingly during the upcoming industrial user permit (IUP) renewals. NPDES Permit Limits: Spindale’s current permit requires compliance with copper and silver limits by July 1, 2024. Increased monitoring of the industries over the past two years does not indicate the three IUPs are causing pass through. The Town’s residuals data have been below the ceiling concentrations for copper and silver under Permit No. WQ0001953. Industry Inspection: A site visit of Manual Woodworkers and Weavers was conducted which included review of the most recent industry inspection and a tour of the facility. In the December 2021 industry inspection, the Town had concerns regarding secondary containment, which appeared to have been adequately addressed at the time of the site visit on May 17, 2022. Enforcement Response Plan (ERP): All industries have a copy of the Town’s current ERP. To aid in semi-annual sampling, the Town will establish required sampling months for the industries , which will be reflected in the new IUPs. NC0020664 17 (Cont.) Page#2 DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A Permit:NC0020664 Inspection Date:05/17/2022 Owner - Facility: Inspection Type: Spindale WWTP Pretreatment Audit Yes No NA NE Page#3 DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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 Spindale WWTP 2. Control Authority Representative(s): Guy O’Connor 3. Title(s): ORC 4. Address of POTW: Mailing 327 Ecology St. City Spindale Zip Code 28160 Phone Number 828-286-3407 Fax Number E-Mail goconnor@spindalenc.net 5. Audit Date 05/17/2022 6. Last Inspection Date: 06/11/2019 Inspection Type: PCI Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program 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. One chlorine exceedance due to equipment failure. 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 0 6 6 4 05 17 22 10. Current Number of Significant Industrial Users (SIUs)? 3 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: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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 I nfo: Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/13/2020 Yes No Yes No Industrial Waste Survey (IWS) 1/3/2019 Yes No 1/10/2019 Yes No 12/31/2023 Sewer Use Ordinance (SUO) 12/31/2021 Yes No 1/10/2019 Yes No Enforcement Response Plan (ERP) 1/22/2020 Yes No 2/12/2020 Yes No Long Term Monitoring Plan (LTMP) 06/28/2019 Yes No 01/10/2019 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 2013, The Town is currently in the process of adopting the revised SUO for 2022. 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 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 Reference Materials S M U Reference materials are online; however, need additional training to interpret regulations and implementation. Staff Training (i.e. Annual and Regional Workshops, Etc.) S M U There has not been routine pretreatment training provided by the State for the past couple of years. Computer Equipment (Hardware and Software) S M U DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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. WWTP recently received new computers. 31. How does the POTW recover the cost of the P retreatment Program from their industries? Explain. Higher water rates charged to industries versus residents. 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? Arrangements would be made to have the public come to the WWTP to review any requested records. 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? Staff would determine if anything were proprietary and if not essential to maintaining the pretreatment program, they would not keep on -site. If needed, it would be labeled as such in the files and not available for public review. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes No Regularly communicate with the industries when picking up samples but do not schedule meetings regularly unless there are process changes, or the industries have questions. 36. Is the public notified about changes in the SUO or Local Limits? Yes No Public hearing for new ordinances and the Town is working on updating their website to host more information. 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? Required to apply for a permit by the Town. 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?) Depends on classification of industry and whether it falls into the category of an SIU or CIU by regulations. Will determine flow and type of waste stream. 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) Maintain logs and require septage haulers to discharge at a designated point upstream of the headworks. 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? Silver, this was approved during last HWA submittal; however, the new HWA is currently under review by Central Office but has not been approved yet. 45. If yes to #44, What is being done to address the over allocations? (short -term IUPs, HWA to be revised, pollutant study, etc.) Town staff are reviewing the reason for the previous overallocation, and Central Office is currently reviewing. Current limit in facilities IUP is not needed by industry and no issue with silver in the effluent based on increased monitoring over the past couple of years. DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No If yes, what percentage of each parameter 80% Have at least 80% of most parameters because flows are minimal from industries. 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) Based on NPDES permit limits and any CIU requirements. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Based on Long-term monitoring plan requirements. 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 outco me of the adjudication? 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. Facility reviews data quarterly and adjusts monitoring as needed. The Town is now requiring permittees to conduct semi-annual sampling earlier in the sixth month period to allow adequate time for resampling as needed. This will be reflected in the new IUPs. 52. Does the POTW use the Division’s model inspection form or equi valent? 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? Whether any areas within the facility have the potential to adversely impact the WWTP. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Whether they have mitigation measures to prevent a spill to drains and their containment response should there be a spill. 56. How does the POTW decide where the sample point for an SIU should be located? Before it enters the main sanitary line and whether it is representative of the waste stream. 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 and facilities utilize a composite sampler to collect representative samples. Collection months will also be detailed in the upcoming IUPs. 58. Who performs sample analysis for the POTW for Metals Water Tech Conventional Parameters Water Tech Organics Water Tech 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. POTW utilizes Water Tech to courier collected samples and uses their laboratory Chains of Custody. The auto samplers are setup at each facility and samples are collected the next day and brought back to the WWTP for courier pickup. CoC travels with samples. Water Tech subcontracts metals and organics. Timken now contracts with PACE to set up and collect samples. 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:________________________________ DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 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 Explain. HWA is currently under review in Raleigh. They may address an overallocation for silver since it’s not needed by the industry and the WWTP currently has a pending silver limit. 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. Facility recently went through an upgrade and there are currently adequate fields under Spindale’s RLAP and US Biosolids permit. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No changes planned. DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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. Ultimate Textile 2. Manual Woodworkers 3. Timken 67. IUP Number 008 003 004 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 06/20/23 06/20/23 06/30/23 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A NA NA 433.17 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, D oes 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 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 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: DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A 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 0 6 6 4 5 17 22 1. Industry Inspected: Manual Woodworkers and Weavers 2. Industry Address: 100 Spindale St. Spindale, NC 28160 3. Type of Industry/Product: Textile 4. Industry Contact: Jack Waters Title: Maintenance Supervisor Phone: 828-287-5599 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 next industry inspection will be conducted by the Town at the end of the year. This site visit went through areas of concern brought up during the December industry inspection. The industry had corrected a secondary containment issue that had the potential to discharge to the sewer. The SIU inspection from December was reviewed during the site visit. Water usage was down due to decreased demand. Audit SUMMARY AND COMMENTS: Audit Comments: Overall the system is being well maintained and staff are learning the requirements of managing all aspects of the program. Requirements: HWA is under review in Central Office. IWS is due in 2023. Recommendations: It is recommended the Town attend the next pretreatment training offered by the State. If trainings are unavailable through the Division’s pretreatment unit, Town personnel may wish to reach out to neighboring pretreatment programs as needed. NOD: Yes No NOV: Yes No QNCR: Yes No POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: Mikal Willmer DATE: 05/17/2022 Mikal Willmer, Asheville Regional Office DocuSign Envelope ID: C2CC5442-0472-4874-8016-2ED3EAD11B3A