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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