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HomeMy WebLinkAboutNC0023965_Pretreatment Compliance Inspection_20220629DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality July 5, 2022 Mr. William Roy, Environmental Compliance Manager Cape Fear Public Utility Authority 235 Government Center Drive Wilmington, NC 28403 Subject: Pretreatment Compliance Inspection Program: CFPUA- James A. Laughlin, M'Kean Maffitt WWTP's NPDES Permit No. NC0023965 & NC0023973 New Hanover County Dear Mr. Roy: A Pretreatment Compliance Inspection of the CFPUA Wastewater Treatment Facilities was conducted by Helen Perez from this office on June 29, 2022. This inspection was conducted to determine the effectiveness of the pretreatment program by reviewing various aspects of the program, which included files and records, industrial user inspections and monitoring data, data management procedures and adherence to the Enforcement Response Plan. The CFPUA continues to do an effective job of achieving the pretreatment program goals. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report. There were no significant issues or findings noted during this inspection thus a response to this inspection report is not required. Thank you for your continued support of the North Carolina Pretreatment Program. If you should have any questions, please contact Helen Perez at (910) 796-7323 or at helen.perez@ncdenr.gov . Cc: Upload to Laserfiche Sincerely, DocuSigned by: (±1-04n- 7F141E73B6F3456... Tom Tharrington, Assistant Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405 910.796.7215 DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 1� D_E Department m Enmmamemai oval; North Carolina Department of Environmental Quality I Division of Water Resources Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405 910.796.7215 DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)I 1. Control Authority (POTW) Name: Cape Fear Public Utility Authority 2. Control Authority Representative(s): Willaim Roy, Maggie Butler 3. Title(s): Environmental Compliance Manager, Environmental Compliance Supervisor 4. Last Inspection Date: 04/21/2021 Inspection Type (Check One): ❑ 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 ICIS CODING Main Program Permit Number N1C101012131916151 MM/DD/YY J06 129 120221 7. Current Number Of Significant Industrial Users (SIUs)? 7 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)? 2 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? 20. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ❑ YES /1 NO ❑ YES I1 NO Limits: N/A Reporting: N/A lished: N/A N/A ❑ YES I1 NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 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 Division Inspector, please verify yourself! 26. If NO to 23 - 26, list violations 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info: Program Element NC0023965 Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 05/24/2022 /1 Yes ❑ No ❑ Yes ❑ No Industrial Waste Survey (IWS) 07/18/2018 /1 Yes ❑ No 07/31/2018 /1 Yes ❑ No 08/01/2023 Sewer Use Ordinance (SUO) 12/29/2016 /1 Yes ❑ No 03/21/2017 /1 Yes ❑ No Enforcement Response Plan (ERP) 11/07/2019 /1 Yes ❑ No 02/05/2020 /1 Yes ❑ No Long Term Monitoring Plan (LTMP) 12/07/2018 /1 Yes ❑ No 12/12/2018 /1 Yes ❑ No — Program Element NC0023973 Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 06/27/2019 /1 Yes ❑ No 08/07/2019 1 Yes ❑ No 06/30/2024 Industrial Waste Survey (IWS) 07/18/2018 r Yes ❑ No 07/31/2018 I4 Yes ❑ No 08/01/2023 Sewer Use Ordinance (SUO) 12/29/2016 /1 Yes ❑ No 03/21/2017 I4 Yes ❑ No Enforcement Response Plan (ERP) 11/07/2019 /1 Yes ❑ No 02/05/2020 1 Yes ❑ No Long Term Monitoring Plan (LTMP) 12/07/2018 r Yes ❑ No 12/12/2018 1 Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION 29. User Name 1. SR&R I 2. New Hanover Regional Medical Center 3. New Hanover County Landfill 30. IUP Number N2012A S-143 N2021A 31. Does File Contain Current Permit? 11 Yes ❑ No 11 Yes ❑ No 11 Yes ❑ No 32. Permit Expiration Date 06/30/2025 06/30/2025 12/21/2023 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 437D N/A N/A 34. Does File Contain Permit to Permit Issue Date? Application Completed Within One Year Prior A Yes ❑ No /1 Yes ❑ No A Yes ❑ No 35. Does File Contain an Inspection Completed Within Last Calendar Year? 1 Yes ❑ No /1 Yes ❑ No 1 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 ANo b. •Yes @ No a. -Yes •No b. •Yes ■ No a. ■Yes ANo b. •Yes @ No 37. 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 38. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. Yes ■No b.❑Yes❑No®N/A a. AYes ■No b.❑Yes❑No®N/A a. Yes ■No b.❑Yes❑NoNN/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? 1 Yes ❑ No r Yes ❑ No 1 Yes ❑ No 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? 1 Yes ❑ No /1 Yes ❑ No 1 Yes ❑ No 1 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? 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? c. If applicable, Did POTW resample within 30 days of becoming aware of SIU limit violations in the POTW's sampling of the SIU? 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? 49. Does The File Contain Proof Of Penalty Collection? 50. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑NOON/A ❑Yes❑No®N/A ❑Yes❑NOON/A ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A r Yes ❑ No // Yes ❑ No A Yes ❑ No ®Yes❑No❑N/A ®Yes❑No❑N/A ®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 a.®Yes❑No❑N/A b.®Yes❑No❑N/A c.®Yes❑No❑N/A ❑ Yes ICI No ❑ Yes 0 No ■Yes A No ®Yes❑No❑N/A ❑Yes❑No®N/A ®Yes❑No❑N/A ®Yes❑No❑N/A ❑ Yes ❑NoEIN/A ❑Yes®No❑N/A ®Yes❑No❑N/A ❑Yes❑NoON/A ❑Yes❑NoON/A a.❑Yes❑NoEIN/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑NoEIN/A a.❑Yes❑NoEIN/A b.❑Yes❑NolaN/A ❑ Yes 1 No ❑ Yes /1 No ❑ Yes 1 No FILE REVIEW COMMENTS: 28. The HWA for the Northside WWTP (NC0023965) was submitted on May 24, 2022 and currently in review. 34. New Hanover County Landfill - Became a SIU effective October 1, 2021 but has had a Pretreatment Permit with CFPUA prior to this date. 36. SR&R and New Hanover County Landfill — Waste is hauled to POTW so Slug/Spill Control Plan is not required. 48. New Hanover County Landfill - Issued 2 NOVs in March for failure to sample in February 2022. Civil Penalties will be assessed after receiving and reviewing all data for the Semi -Annual Period. INDUSTRY INSPECTION ICIS CODING: N/A Main Program Permit Number MM/DD/YY 1. Industry Inspected: 2. Industry Address: 3. Type of Industry/Product: 4. Industry Contact: Phone: Fax: Title: 5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ YES ❑ NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 DocuSign Envelope ID: 9C759DC6-8046-4292-B7AE-F42DB6586E29 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: OVERALL SUMMARY AND COMMENTS: Comments: All records were detailed, organized and readily available for review. CFPUA continues to manage an effective Pretreatment Program. Requirements: N/A Recommendations: None NOD: ❑ YES ®NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory X Marginal Unsatisfactory PCI COMPLETED BY: Helen Perez — Wilmington Regional Office DATE: 7/5/2022 rRthDocuSigned by: 1D645B4A39694BE... —DocuSigned by: -TOM- -Tinetri 0w. '-7F141E73B6F3456... 7/5/2022 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4