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Home My WebLink AboutNC0021547_Pretreatment Compliance Inspection_20220825 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. August 25, 2022 Amanda W Owens Town of Franklin Email: aowens@franklinnc.com SUBJECT: Compliance Inspection Report Franklin WWTP NPDES WW Permit No. NC0021547 Macon County Dear Permittee: The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection (PCI) of the Town of Franklin Pretreatment Program on August 15, 2022. This PCI 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 Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667 or via email at lauren.armeni@ncdenr.gov. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Reports Ec: Laserfiche Bill Deal (Public Works Director/Pretreatment Coordinator/ORC) DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A 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 NC0021547 22/08/15 P 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) Franklin WWTP Sierra Dr Franklin NC 28734 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 22/08/15 19/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// William Logan Deal/ORC/828-524-2516/ Other Facility Data 12:00PM 22/08/15 23/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number Amanda W Owens,PO Box 1479 Franklin NC 287441479/Town Manager/828-524-2516/ Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Other 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: BBA6044B-E328-4778-A5D1-41210CCE381A 8/26/2022 8/26/2022 8/26/2022 8/27/2022 NPDES yr/mo/day 22/08/15 Inspection Type P3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Mikal Willmer, and Stephanie Williams, with the Asheville Regional Office, conducted a Pretreatment Compliance Inspection (PCI) of the Town of Franklin’s Pretreatment Program on August 15, 2022. Bill Deal (Public Works Director/Pretreatment Coordinator/ORC) was present during the inspection. Overall, the program appears to be in compliance with Federal and State Pretreatment requirements. The Franklin Pretreatment Program has one SIU which is the Macon County Landfill. Currently, there are no over allocations and all sampling is being conducted per program requirements. Please reference the attached PCI form for inspection details. NC0021547 17 (Cont.) Page#2 DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Franklin WWTP 2. Control Authority Representative(s): Bill Deal 3. Title(s): Public Works Director/Pretreatment Coordinator/ORC 4. Last Inspection Date: 05/23/2018 Inspection Type (Check One): PCI X Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? X YES NO 6. Is POTW under an Order That Includes Pretreatment Conditions? YES X NO Order Type, Number, Parameters: _______________________________ Are Milestone Dates Being Met? YES NO ICIS CODING Main Program Permit Number MM/DD/YY | N | C | 0 | 0 | 2 | 1 | 5 | 4 | 7 | | 08 | 15 | 22 | 7. Current Number Of Significant Industrial Users (SIUs)? 1 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? 1 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)? 0 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? YES X NO 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? YES NO 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 Limits: 1 - Macon County Landfill SNC for Reporting: 0 Not Published: 0 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? 0 21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? YES NO 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 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:_______________________ DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 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 Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 03/23/21 Yes No Review hasn’t been completed. Yes No N/A Industrial Waste Survey (IWS) 04/03/19 Yes No 06/21/19 Yes No 04/01/24 Sewer Use Ordinance (SUO) 12/20/12 Yes No 01/02/13 Yes No N/A Enforcement Response Plan (ERP) 02/05/20 Yes No 02/13/20 Yes No N/A Short Term Monitoring Plan (STMP) 08/03/16 Yes No 10/20/16 Yes No N/A ________________________________________________________________________________________________________________ INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Macon County Landfill 2. 3. 30. IUP Number 0002 31. Does File Contain Current Permit? Yes No Yes No Yes No 32. Permit Expiration Date 07/31/26 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No 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 No 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. Yes No b.Yes No N/A a. Yes No b.Yes No N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? Yes No Yes No Yes No 40. Does File Contain POTW Sampling Chain-Of-Custody Forms? Yes No Yes No Yes No 41. 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 No N/A Yes No N/A Yes No N/A 42b. 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 43a. During the Most Recent Semi-Annual Period, Did the POTW Identify All Limits Non-Compliance from Both POTW and SIU Sampling? Yes No Yes No Yes No 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/A Yes No N/A Yes No N/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? c. If applicable, Did POTW resample within 30 days of becoming aware of SIU limit violations in the POTW’s sampling of the 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 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No Yes No Yes No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? Yes No N/A Yes No N/A Yes No N/A 48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A 49. Does The File Contain Proof Of Penalty Collection? Yes No N/A Yes No N/A Yes No N/A 50. a. Does the 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 DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? Yes No Yes No Yes No FILE REVIEW COMMENTS: Mr. Deal collects samples for the POTW, and Earth Environmental Services collects samples for the industry. All samples are analyzed by Earth Environmental Services. Both the POTW and industry sampling results are sent to Mr. Deal, and he prints the industry results and takes them to the industry. Macon County Landfill (SIU) was in SNC for cyanide during the January 2022 – June 2022 semi-annual sampling period. A Notice of Violation was sent to the industry and a Public Notice was issued by the Town of Frankl in, per the ERP requirements. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY | | | | | | | | | | | | | | 1. Industry Inspected:________________________________________________________________________________________ 2. Industry Address:__________________________________________________________________________________________ 3. Type of Industry/Product:___________________________________________________________________________________ 4. Industry Contact:________________________________________Title:_____________________________________________ Phone:__________________________________________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: N/A – A PCI was conducted; therefore, the industry inspection was not required. A file review was conducted, and the industry inspection performed in 2021 by Mr. Deal was reviewed. OVERALL SUMMARY AND COMMENTS: Comments: Overall, the Pretreatment Program appears to be well-managed. Documents and sampling data are organized well and kept in binders by year. Sampling data is now being entered into the Compliance Judgement spreadsheet. Requirements: ______________________________________________________________________________________________ __________________________________________________________________________________________________________ Recommendations: ____________________________________________________________________________________________ __________________________________________________________________________________________________________ NOD: YES NO DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4 NOV: YES NO QNCR: YES NO POTW Rating: Satisfactory X Marginal Unsatisfactory PCI COMPLETED BY: Lauren Armeni DATE: 08/15/2022 DocuSign Envelope ID: BBA6044B-E328-4778-A5D1-41210CCE381A