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NC0021491_202206PCI_20230726
NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Wafter Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION 1Comnlete Prior To PCI: Review Program Info Database Sheets 1. Control Authority (POTW) Name: Town of Mocksville 2. Control Authority Representative(s): Kenneth Gamble, Madelyn Mills, Joshua Powers 3. Title(s): Town Manager, Compliance Coordinator (Envirolink) Pretreatment Coordinator (Environlink) 4. Last Inspection Date: 8/1/2022 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 NC 0021491 Permit expires: 3/1/23 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? 1 * * 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)? 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? 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) SIU had 2 BOD violations in July 2022, not in SNC. Issued NOV for limit violations. 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? ® YES ❑ NO -DO (NOD)5/2022 -TSS (NOV)1/2022 Isolated, no remediation actions ❑ YES ® NO SNC for Limits: 0 SNC for Reporting: 0 Not Published: 0 None ❑ YES ® NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 1 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 (Division 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 N NO If yes, which ones? Eliminated: Added: 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) 1/12/2022 N Yes ❑ No Pending ❑ Yes ❑ No Pending Industrial Waste Survey (IWS) 5/4/2020 N Yes ❑ No 7/27/2020 N Yes ❑ No 6/30/2024 Sewer Use Ordinance (SUO) 6/1/2014 N Yes ❑ No 6/11/2014 N Yes ❑ No na Enforcement Response Plan (ERP) 3/4/2020 N Yes ❑ No 3/17/2020 N Yes ❑ No na Short Term Monitoring Plan (STMP) 8/28/2018 N Yes ❑ No 12/3/2018 N Yes ❑ No na NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 2 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND I iU INSPECTION) 29. User Name IFBrakebush Bros 3. 30. IUP Number 0004 31. Does File Contain Current Permit? M Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 32. Permit Expiration Date 3/8/2025 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or NA I F N/A 34. Does File Contain Permit Application Completed ❑ Yes N No F ❑ Yes ❑ No �F ElYes El No Within One Year Prior to Permit Issue Date? 35. Does File Contain an Inspection Completed Within ❑ Yes M No I ❑ Yes ❑ No F El Yes El No Last Calendar Year? 36. a. Does the File Contain a Slug/Spill Control Plan? a ❑ Yes N No a. ❑ Yes ❑ No a. ❑ Yes ❑ No b. If No, is One Needed? (See Inspection Form from b. ❑ Yes N No b. ❑ Yes ❑ No b. ❑ Yes ❑ No POTW) 37. For 40 CFR 413 and 433 TTO Certification, Does ❑ Yes ❑ No N NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA File Contain a Toxic Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter a. ❑Yes NNo ❑Yes ❑No a. ❑Yes ❑No from the Division? b. All Issues Resolved? b.❑ Yes ❑ No N/A ® Yes ❑ No N/A ❑ b.❑ Yes ❑ No N/A ❑ 39. During the Most Recent Semi -Annual Period, Did the N Yes ❑ No N Yes ❑ No ❑ Yes ❑ No POTW Complete its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of- 11 N Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Custody Forms? 41. During the Most Recent Semi -Annual Period, Did the N Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA SIU Complete its Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did M Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA SIU submit all reports on time? 42a. For categorical IUs with Combined Wastestream ❑ Yes ❑ No N NA ❑ Yes ❑ No ❑ NA M Yes ❑ No ❑ NA Formula (CWF), does file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, ❑ Yes ❑ No M NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA does file include production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did N Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did ❑ Yes ❑ No M NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA the POTW Identify All Reporting_Non-Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) a. ❑ Yes ❑ No ® NA a. ❑ Yes ❑ No ❑ NA a. ❑ Yes ❑ No ❑ NA of All Self- Monitoring Violations? b. Did Industry Resample and submit results to POTW b ❑ Yes ❑ No ® N/A ❑ Yes ❑ No ❑ N/A b ❑ Yes ❑ No ❑ N/A Within 30 Days? c. If applicable, Did POTW resample within 30 days c. ❑ Yes ❑ No ® N/A _❑ No ❑ N/A c. ❑ Yes ❑ No ❑ N/A of becoming aware of SIU limit violations in the POTW's sampling of the SIU? 46. During the Most Recent Semi -Annual Period, Was ❑ Yes M No ❑ Yes ❑ No ❑ Yes ❑ No the SIU in SNC? 47. During the Most Recent Semi -Annual Period, Was ❑Yes ❑ No 0 N/A ❑Yes ❑ No ❑ N/A El Yes ❑ No ❑ N/A Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑ Yes ❑ No N NA ❑ No ❑ NA ❑ Yes ❑ No ❑ NA NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 3 49. Does The File Contain Proof Of Penalty Collection? 50. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? FILE REVIEW COMMENTS: ❑ Yes ❑ No ❑x NA 11 ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA a. ❑ Yes ❑ No N/A © a. ❑ Yes ❑ No N/A ❑ a. ❑ Yes ❑ No N/A ❑ b ❑ Yes ❑ No N/A E b ❑ Yes ❑ No N/A ❑ b ❑ Yes ❑ No N/A ❑ ❑X Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Inspector did not see IU application (04), IU permit approval letter from the Division (08), and no inspection was conducted in 2022 (#35**). STMP was in order. NO AUDIT CONDUCTED OVERALL SUMMARY AND COMMENTS: Comments: The pretreatment program did not conduct and document an inspection for 2022. The IU permit application, nor a Division IU permit approval letter was not in files given to inspector for review. The PPS form in PAR was marked 0 for `number of SIUs NOT inspected by POTW', but no inspection form was in file. Mr. Powers indicated a visit (not inspection) of the SIU was conducted. PAR was inadequate when submitted in March 2023. Permittee did submit more documentation, however an allocation table was not submitted. Requirements: Per 15A NCAC 02H .0905(a): POTW pretreatment program requirements promulgated by the EPA and codified as 40 CFR 403.8 (f) and (g) are hereby incorporated by reference. 40 CFR 403.8 (f)(2)(v) states Control Authorities are required to inspect and sample all SIUs a min of once per year. Per 15A NCAC 02H .0916 (c)(4)(A): An allocation table (AT) listing permit information for all SIUs, including permit limits, permit effective and expirations dates, and a comparison of total permitted flows and loads with Division approved maximum allowable loadings of the POTW, including flow, on forms or in a format provided by the Division. The AT shall be updated as permits are issued or renewed, and as permits are modified where the permitted limits or other AT information is revised; Recommendations: Issue Notice of Violation for failure to conduct annual SIU inspection. Keep relevant documentation in SIU files (ie: IU permit application and Division approval letter). Submit allocation table as soon as possible to Division. NOD: ❑YES ® NO NOV: ®YES ❑ NO QNCR: ®YES LINO POTW Rating: Satisfactory ❑ Marginal ❑ Unsatisfactory PCI COMPLETED BY: Tricia Lowery DATE: 6/28/2023 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 4