HomeMy WebLinkAboutNC0023906_Pretreatment Compliance Inspection_20221014DocuSign Envelope ID: DBB7E266-1BF9-4773-AB11-916B0D88EA23
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Jimmy Pridgen
Water Reclamation Manager
City of Wilson
P.O. Box 10
Wilson, NC 27894-0010
NORTH CAROLINA
Environmental Quality
October 14, 2022
Subject: Pretreatment Compliance Inspection
City of Wilson - Hominy Creek Wastewater Management Facility
NPDES Permit No. NC0023906
Wilson County
Dear Mr. Pridgen:
On August 17, 2022, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of City of Wilson's pretreatment program. The assistance given by Ms. Laura
Pruitt, the Water Reclamation Compliance Coordinator, was greatly appreciated. The inspection report
is attached. Findings during the inspection were as follows:
1. The City has 11 Significant Industrial Users (SIUs), 9 of which are also Categorical Industrial
Users (CIUs). It was noted that no SIUs were in Significant Non -Compliance (SNC) during the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Evens Machinery (Permit No. 2000-015), Eon
Labs (Permit No. 2000-025) and Refresco Beverages (Permit No. 9726). The files needed for
review were available for inspection, contained all the required elements and were in excellent
condition. During the most recent 6-month period, Eon Labs was compliant. Evens Machinery
had one pH violation. Refresco Beverages submitted December 2021 flow report and semi-
annual sampling report late and had five BOD violations. The POTW took appropriate
enforcement actions against these violations.
3. A review of the files containing the pretreatment program elements was conducted. All files
were available and up to date. Long Term Monitoring Plan (LTMP) were updated and approved
recently. It was noted that in the recently approved LTMP, detection limits for arsenic,
lead, and oil & grease were higher than the NC DEQ Published Detection Limit Values.
4. LTMP data were reviewed, it was noted that all parameters were sampled at required locations
and analyzed with required detection levels. LTMP data was well organized and maintained.
NORTH CAROLINA
oay,rorem or Environmental ou.i�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200
DocuSign Envelope ID: DBB7E266-1BF9-4773-AB11-916B0D88EA23
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at (919) 791-4200 (or email: cheng.zhang@ncdenr.gov).
Enclosure: City of Wilson PCI Inspection Form
CC: Laserfiche
Laura Pruitt, City of Wilson (Electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
Sincerely,
,-DocuSigned by:
J1M t,SSA. f.
'-B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000
DocuSign Envelope ID: DBB7E266-1BF9-4773-AB11-916B0D88EA23
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)1
1. Control Authority (POTW) Name: City of Wilson
2. Control Authority Representative(s): Laura Pruit
3. Title(s): Water Reclamation Compliance Coordinator
4. Last Inspection Date: 8/28/2020 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 MM/DD/YY
1 1v I C I 0 I 0 1 2 L 3 19 I O 16 J 08 117 I
7. Current Number Of Significant Industrial Users (SIUs)?
11
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)?
9
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?
Flow in 1/2021 and 2/2021, caused by excessive rain fall.
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?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
/1 YES ❑ NO
❑ YES /1 NO
Limits: None
Reporting: None
fished: None
N/A
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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 effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself!
26. IfNO to 23 - 26, list violations
❑ NO
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
DocuSign Envelope ID: DBB7E266-1BF9-4773-AB11-916B0D88EA23
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 Approva 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)
3/29/2018
0 Yes ❑ No
6/5/2018
0 Yes ❑ No
4/1/2023
Industrial Waste Survey (IWS)
5/30/2019
/1 Yes ❑ No
8/15/2019
/1 Yes ❑ No
6/1/2024
Sewer Use Ordinance (SUO)
2/12/2012
a Yes ❑ No
3/12/2012
r Yes ❑ No
Enforcement Response Plan (ERP)
2/12/2020
a Yes ❑ No
2/14/2020
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/10/2022
Yes ❑ No
6/23/2022
r Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Evens Machinery 2. Eon Labs
3. Refresco Beverages
30. IUP Number
2000-015
2000-025
9726
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
12/31/2026
12/31/2024
6/30/2023
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
439D
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
i1 Yes ❑ No
@ 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. ►EYes •No
b. •Yes •No
a. AYes •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❑NoEN/A
❑Yes❑NoEN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. A Yes ■ No
b.❑Yes❑No❑N/A
a. ►E Yes ■ No
b.❑Yes❑No❑N/A
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?
/1 Yes ❑ No
/1 Yes ❑ No
0 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
/1 Yes ❑ No
A 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
NYes❑No❑N/A
❑YesNNo❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NoEN/A
®Yes❑No❑N/A
❑Yes❑NoEN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
EYes ❑No❑N/A
❑Yes❑NoEN/A
EYes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
EYes❑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❑NoEN/A
b.❑Yes❑NoEN/A
c.®Yes❑No❑N/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
a.❑Yes❑NoEN/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 /1 No
❑ Yes L No
❑ Yes /1 No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
EYes ❑No❑N/A
❑Yes❑NoEN/A
EYes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes ONO EN/A
❑Yes❑NoEN/A
EYes ❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes r No
❑ Yes I No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
DocuSign Envelope ID: DBB7E266-1BF9-4773-AB11-916B0D88EA23
FILE REVIEW COMMENTS:
41b — Refresco Beverages submitted December 2021 flow report and semi-annual sampling report late.
43a — Evens Machinery had one pH violation. Refresco Beverages had five BOD violations.
47 — POTW issued one NOV to Evens Machinery and four NOVs to Refresco Beverages.
48 — POTW assessed $4000 civil penalty to Refresco Beverages.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I I I
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
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: The program is well managed.
Requirements: None
Recommendations: Modify LTMP by using the lowest PQLs for arsensic, lead, and O&G.
NOD: ❑ YES ® NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 17, 2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3