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Home My WebLink AboutNC0021547_Pretreatment Compliance Audit_20230725 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. July 25, 2023 Amanda W Owens Town of Franklin Email: aowens@franklinnc.com SUBJECT: Pretreatment Compliance Audit Franklin WWTP NPDES WW Permit No. NC0021547 Macon County Dear Permittee: The North Carolina Division of Water Resources conducted a Pretreatment Compliance Audit (PCA) of the Town of Franklin Pretreatment Program on 7/17/2023. The PCA 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", as well as the Pretreatment Audit 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@deq.nc.gov. Sincerely, Lauren Armeni, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report, Pretreatment Audit Report Ec: Laserfiche Jason Hopkins (ORC) DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E 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 23/07/17 G 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 10:30AM 23/07/17 19/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jason Dean Hopkins/ORC/828-524-2516/ Other Facility Data 01:00PM 23/07/17 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/ Mara G Chamlee DWR/ARO WQ/828-296-4500/ Rachel Rose DWR/ARO WQ/828-296-4500/ 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: 366335C2-112A-45DF-96F1-9B62B2EBFC9E 7/25/2023 7/25/2023 7/25/2023 7/25/2023 NPDES yr/mo/day 23/07/17 Inspection Type G3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Mara Chamlee, and Rachel Rose, with the Asheville Regional Office, conducted a Pretreatment Compliance Audit (PCA) of the Town of Franklin’s Pretreatment Program on July 17, 2023. Jason Hopkins (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. Macon County landfill was in SNC for cyanide during both 6-month sampling periods in 2022; however, they were not in SNC during the first 6-month sampling period in 2023. Mr. Hopkins believes the cyanide came from the new plastic liners/pipes from the landfill opening a new cell. He will continue to monitor and take action as needed. Please reference the attached Pretreatment Audit Report for inspection details. NC0021547 17 (Cont.) Page#2 DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E Permit:NC0021547 Inspection Date:07/17/2023 Owner - Facility: Inspection Type: Franklin WWTP Pretreatment Audit Other Yes No NA NE See summary for details.Comment: Page#3 DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Franklin WWTP 2. Control Authority Representative(s): Jason Hopkins 3. Title(s): ORC/Pretreatment Coordinator 4. Address of POTW: Mailing 399 Sierra Lane City Franklin Zip Code 28734 Phone Number 828-524-2516 Fax Number E-Mail jhopkins@franklinnc.com 5. Audit Date 07/17/2023 6. Last Inspection Date: 08/15/2022 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 MM/DD/YY N C 0 0 2 1 5 4 7 07 17 23 10. Current Number of Significant Industrial Users (SIUs)? 1 11. Number of SIUs with No IUP, or with an Expired IUP ? 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? 1 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)? 0 19. Number of CIUs in SNC? 0 DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 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) 03/23/21 Yes No Review hasn’t been completed. Yes No 04/01/26 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 Legal Authority (Sewer Use Ordinance-SUO) 21. Do you have any towns and/or areas from which you receive waste water which are not in your annexed jurisdiction? Yes No If yes, Please list these towns and/or areas. 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 02/04/14 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 N/A Resources 29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW’s Pretreatment Program S M U Access to POTW Vehicles for Sampling, Inspections, and Emergencies S M U Access to Operable Sampling Equipment S M U Availability of Funds if Needed for Additional Sampling and/or Analysis S M U Reference Materials S M U Staff Training (i.e. Annual and Regional Workshops, Etc.) S M U Computer Equipment (Hardware and Software) S M U DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No Explain Yes or No. 31. How does the POTW recover the cost of the Pretreatment Program from their indu stries? Explain. The Town bills the County because the POTW samples for the County. Additionally, the POTW and landfill have an agreement – the landfill takes the POTW’s sludge that has been belt pressed and the POTW treats the landfill’s leachate. 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 proce dure for keeping files confidential from public. If no how would the request be addressed? The request would not remain confidential if it endangered the public in any way, otherwise they would evaluate on a case -by-case basis. 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 37. Were all industries in SNC published in the last notice? Yes No Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? The applications are left in Town Hall and once they are filled out, they are sent to Mr. Hopkins. 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?) Mr. Hopkins receives a letter from Macon County Landfill every six months that verifies nothing has changed. For new industries, Mr. Hopkins follows the three rules to determine if the industry is considered a n SIU, and if they do meet the three rules then the industry must fill out an IWS short form, then an IWS long form if needed. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? Yes No If Yes, How many are there? 1 Please list each site and how it is permitted, if applicable. Macon County Landfill - IUP 41. Does the POTW accept waste by (mark if applicable) Truck Dedicated Pipe NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) The POTW has a designated dump station screen prior to the automatic bar screen, so the waste is screened twice before entering the EQ basin. The septage haulers are required to keep a log. 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: 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.) 46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No If yes, what percentage of each parameter % DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 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) Initially the industry fills out a short form to see if they’d qualify as an SIU, then if they do the long form is sent to th e industry. The long form lets the Town’s contract engineers determine the industry’s categorical parameters, which would then determine the appropriate pollutants to monitor for. Additionally, the HWA also helps determine which pollutants to limit in the permit. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Based on pretreatment regulations, currently in the IUP they’re required to sample once every six months. 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? 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporti ng requirements, and permit conditions, as well as for SNC. Mr. Hopkins indicated that they use a compliance judgement spreadsheet for SNC and they follow the ERP as needed. 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? Through sampling if spikes are seen. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? N/A – not required for the landfill. 56. How does the POTW decide where the sample point for an SIU should be located? After all waste streams are mixed. In the case of the landfill, it’s after the leachate from all four landfill cells are mixed after the leachate pond. 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each ti me? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: Yes No SIU: Yes No If yes, Explain. The POTW contracts Earth Environmental Services (EES) for all of the sampling. When they come to sample, Mr. Hopkins goes with them. 58. Who performs sample analysis for the POTW for Metals EES Conventional Parameters EES Organics EES 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. All regular CoC procedures are followed. 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? Dewberry Phone ( ) -- DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 62. Do you have plans to revise your HWA in the near future? Yes No 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 d isposal)? Yes No Explain. The Town has extra land to expand the WWTP if needed. The plant was last upgraded in 2012. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Macon County Landfill 2. 3. 67. IUP Number 0002 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 07/21/26 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 72. Does File Contain Inspection Completed Within Last Calendar Year? 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 74. 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 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? Yes No Yes No Yes No 77. Does File Contain POTW Sampling Chain-Of-Custody Forms? 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 No N/A Yes No N/A Yes No N/A 80b. For categorical IUs with Production based limit s, 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? Yes No Yes No Yes No 82. During Most Recent Semi-Annual Period, Did POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/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 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 No N/A Yes No N/A Yes No N/A 86. Does File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A 87. Does File Contain Proof Of Penalty Collection? Yes No N/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 No Yes No Yes No FILE REVIEW COMMENTS: DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E NC DWR Pretreatment Audit Form Revised: December 2016 Page 7 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY N C 0 0 2 1 5 4 7 07 17 23 1. Industry Inspected: Macon County Landfill 2. Industry Address: 1148 Lakeside Drive, Franklin, NC 28734 3. Type of Industry/Product: Landfill 4. Industry Contact: Chris Stahl Title: Director of Solid Waste Management Phone: 828-342-0037 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: Macon County landfill was in SNC for cyanide during both 6 -month sampling periods in 2022; however, they were not in SNC during the first 6-month sampling period in 2023. Mr. Hopkins believes the cyanide came from the new plastic liners/pipes from the landfill opening a new cell. He will continue to monitor and take action as needed. Audit SUMMARY AND COMMENTS: Audit Comments: All files were organized well and were readily available. All inspection questions were thoroughly answered as well as any questions the ARO inspectors had. Requirements: HWA is under review in the Central Office. Recommendations: None. NOD: Yes No NOV: Yes No QNCR: Yes No POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: DATE: Lauren Armeni, Asheville Regional Office DocuSign Envelope ID: 366335C2-112A-45DF-96F1-9B62B2EBFC9E 7/25/2023