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HomeMy WebLinkAboutNC0020290_Pretreatment_Audit_Compliance_Inspection_20230201DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 ROY COOPER Governor ELIZABETH S. RISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. February 1, 2023 Heather Hockaday, Town Manager Town of Burnsville E-mail: hhockaday@townofburnsville.org SUBJECT: Pretreatment Audit Compliance Inspection Report Burnsville WWTP NPDES WW Permit No. NC0020290 Yancey County Dear Permittee: The North Carolina Division of Water Resources conducted a Compliance Audit of the Burnsville WWTP Pretreatment Program on 01/24/2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0020290. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". A Pretreatment Assessment Report (PAR) review was also completed concurrently and also found to be compliant. If you should have any questions, please do not hesitate to contact me with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at tim.heim@ncdenr.gov. Sincerely, DocuSigned by: Ltikogui tAtik 08 1105A3 A4 ... Tim elm . ., Environmental Engineer Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Ec: LF, Shane Dale — Burnsville Public Works Paul Isenhour — Pretreatment Coordinator, Rex Woodie - WWTP ORC D_EQ� Worth Carolina Department of Environmental Qualhy I Division of Water Resources Ashevllk Regional Office 12090 U.S. Highway 70 Swannanoa, North Carolina 28776 625.296.450C DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 United States Environmental Protection Agency EPA 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 1 IN I 2 IL I 3 I NC0020290 111 121 23/01/24 117 Type 18 [ �. j IIIIIIIIIII Inspector Fac Type 191 S I 201 21IIIIII IIIIIIIIIIIIIIIIII I IIIIII P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 671 I 70I I 711 172 I N I 731 I 74 71 I I I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Burnsville WWTP 812 Pine Swamp Rd Burnsville NC 28714 Entry Time/Date 09:OOAM 23/01/24 Permit Effective Date 17/11/01 Exit Time/Date 01:OOPM 23/01/24 Permit Expiration Date 22/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Rex Robert Woody/ORC/828-898-5011/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Shane Dale,PO Box 97 Burnsville NC 287140097/Public Works Director/828-682-2420/ 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 Timothy H Heim DWR/ARO WQ/828-296-4665/ �DocuSignetl by: 2/1/2023 I iwib{iu At iKA Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Rolnt441 tl2/1/2023 gz$22 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 3I NPDES yr/mo/day NC0020290 111 121 23/01/24 117 Inspection Type 18 {j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Tim Heim of the Asheville Regional Office (ARO) performed a Compliance Inspection of the Facility on January 24th, 2023. Paul Isenhour (Pretreatment Coordinator — Water Quality Labs), Rex Woody (ORC), and Robin Surkin (Altec Facility Environmental Manager) were present and assisted with the inspection. The pretreatment program and the single Industrial User (Altec) facility appeared well operated and maintained at the time of the inspection, and in compliance with Permit NC0020290. The following additional items were noted at the time of the inspection: It is recommended that the Pretreatment Coordinator attend the annual NC Pretreatment Consortium on a regular basis for training and continuing education opportunities. https://ncpretreatment.com/ The Pretreatment Coordinator reported a continued good working relationship and communication with the single IU: Altec. Page# 2 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 Permit: NC0020290 Inspection Date: 01/24/2023 Owner - Facility: Burnsville WWTP Inspection Type: Pretreatment Audit Yes No NA NE Page# 3 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Water Resources ENVIRONMENTAL QUALITY Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Town of Burnsville 2. Control Authority Representative(s): Shane Dale/Paul Isenhour/Rex Woody 3. Title(s): Director of Public Works/Pretreatment Coordinator/ORC 4. Address of POTW: Mailing PO Box 97 City Burnsville Zip Code 28714 Phone Number 828-682-2420 Fax Number 828-682-7757 E-Mail sdale(a/townofburnsville.org / waterpualitvlabsAvahoo.com 5. Audit Date 01/24/2023 6. Last Inspection Date: 04/06/22 Inspection Type: ® PCI ❑ Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ❑ No If No, Explain. 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No If Yes, Explain. 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 INICI0I0I2 IO 12 19 I0 1 10. Current Number of Sivnificant Industrial Users (SIUs)? 11. Number of SIUs with No IUP, or with an Expired IUP? MM/DD/YY I 01 I 24 I 23 1 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)? 19. Number of CIUs in SNC? 0 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 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 Info: Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 02/21/2022 01 Yes ❑ No Pending 0 Yes ❑ No 12/01/23 Industrial Waste Survey (IWS) 02/21/2022 II Yes ❑ No Pending I:1 Yes ❑ No 12/01/23 Sewer Use Ordinance (SUO) 05/29/13 /1 Yes ❑ No 05/30/2013 /1 Yes ❑ No NA Enforcement Response Plan (ERP) 05/21/2010 /1 Yes ❑ No 07/16/2010 /1 Yes ❑ No NA Long Term Monitoring Plan (LTMP) 07/17/2016 a Yes ❑ No 07/19/2006 /1 Yes ❑ No NA 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. No ETJ 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 06/24/2013 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 NA Resources 29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfacto Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program a S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and Emergencies /1 S ❑M ❑U Access to Operable Sampling Equipment a S ❑M ❑U Availability of Funds if Needed for Additional Sampling and/or Analysis a S ❑M ❑U Reference Materials Internet Access ►1S ❑M ❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) a S ❑M ❑U Computer Equipment (Hardware and Software) a S ❑M ❑U NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Has computer access and MS Office Suite. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Cost is considered part of "economic development" and there is no surcharge. Sewer rates and billing are based on water usage. 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? 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 confidential from public. If no how would the request be addressed? Determine if information is a trade secret, proceed accordingly. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No 36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No (Per Public Notice Requirements) 37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No NA: No IUs in SNC. Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Inspection of previously identified users and building permit application process. 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?) Survey, sampling as applicable. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ❑ Yes No If Yes, How many are there? NA Please list each site and how it is permitted, if applicable. NA 41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA (Stopped receiving waste from trucks prior to 2018) 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) NA 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: And HWA 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? 45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.) NA 46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No If yes, what percentage of each parameter % (Phosphate is likely limiting parameter) 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) Categorical parameters, WWTP pollutants of concern, industry specific pollutants. NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Potential to impact WWTP. 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 outcome of the adjudication? NA 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting requirements, and permit conditions, as well as for SNC. Sampling results are compared with permit limits. 52. Does the POTW use the Division's model inspection form or equivalent? ® 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? Observation of activities and potential for need. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Evaluation of containment volume. Evaluation of flow paths and materials handling procedures. 56. How does the POTW decide where the sample point for an SIU should be located? Located to sample process flow only. 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Has reviewed sampling procedures. 58. Who performs sample analysis for the POTW for Metals + HCN Pace Labs (Asheville) Conventional Parameters In House Organics In House 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Pace Labs: COC signatures requirements followed, transported on ice, delivered by PTC. In House: Use Commercial Lab COC sheet for procedure. 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: 61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No If no, who completes your HWA? Paul Isenhour Phone (828)898--6277 62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No (Will re-evaluate with new permit) 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. 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. NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No. NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Altec Industries 2. NA 3. NA 67. IUP Number 004 68. Does File Contain Current Permit? 0 Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 69. Permit Expiration Date (Have not received renewal yet) 09/30/20 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? /1 Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 72. Does File Contain Inspection Completed Within Last Calendar Year? /1 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 Certification, Does File Contain a Toxic (TOMP)? ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 74. For 40 CFR 413 and 433 TTO Organic Management Plan 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? 0 Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? Al 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❑NoON/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? i1 Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 82. During Most Recent Semi -Annual Period, Did POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑ Yes ❑NoON/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 1 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❑NoON/A ❑ Yes ❑No❑N/A ❑Yes❑No❑N/A 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑ Yes ❑No❑N/A ❑Yes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑N°ON/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 A No ❑ Yes ❑ No ❑ Yes ❑ No FILE REVIEW COMMENTS: All items requested during the file review were brought to Town Hall for the Inspector. NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 DocuSign Envelope ID: 50C9D670-147E-465E-8CF5-7F109FF2F9F1 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY INICIO 10 1 2 10 1 2 10 10 1 101 1 24 1 23 1 1. Industry Inspected: Altec Industries 2. Industry Address: 150 Altec Drive, Burnsville, NC 3. Type of Industry/Product: Truck Bodies/433 Metal Finisher 4. Industry Contact: Bruce Stainbrook/Robin Surkin Title: Corp Env. Manager/On-site Env. Manager Phone: 770-919-9552/828678-5508 Fax: 828-682-4215 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 industrial facility appeared extremely well run and organized at the time of the inspection. Environmental staff were professional and knowledgeable and maintain excellent communication with the Town of Burnsville Utility and WWTP Staff. The facility implements a number of best practices to mitigate the potential for a spill to occur and be discharged to the sewer. Audit SUMMARY AND COMMENTS: Audit Comments: Continue to maintain best practices and close communication with Town of Burnsville Utility staff. Requirements: NA Recommendations: NA NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory Audit COMPLETED BY: Feoea or: risoguil�u�x Marginal ❑ Unsatisfactory ❑ Tim Heim, P.E., Asheville Regional Office DATE: 01/24/2023 NC DWR Pretreatment Audit Form Revised: December 2016 Page 7