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HomeMy WebLinkAboutNC0025445_202309PCI_20230907ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Nick Holcomb City of Randleman 204 S Main St Randleman, NC 27317-1814 � SfNfo NORTH CAROLINA Environmental Quality September 13, 2023 SUBJECT: Compliance Inspection Report Randleman WWTP NPDES WW Permit No. NCO025445 Randolph County Dear Mr. Holcomb: On 9/7/2023 a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery and Jesse Barnes of the Winston-Salem Regional Office. Lisa Osthues and Michael Glass were present for the inspection. The purpose of this inspection was to determine the effectiveness of the City's pretreatment program, which includes reviewing the files, POTW plant performance, industry monitoring data, and adherence to the enforcement response plan (ERP). Details of the inspection can be found in the Pretreatment Compliance Inspection Report. There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. However, there was an item of concern involving exceeding lead limits of the NPDES permit. Personnel with the City are continuing to work to discover the source of intermittent high lead levels in the collection system. If you should have any questions, please do not hesitate to contact Tricia Lowery with the Division of Water Resources in the Winston-Salem Regional Office at 336-776-9691 or via email at tricia.lowery@deq.nc.gov. Sincerely, DocuSiTgned by: 9451349E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Pretreatment Compliance Inspection Report North Carolina Depariment of En —mental Quality l lAvi ldl of Water Resources Win—S.1em Regional Ol 1 4M West Hanes Mill Road, Svil300 1 Wlnsmn-Salem, N-1, Carolina 27105 336we,9800 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. Control Authority (POTW) Name: City of Randleman 2. Control Authority Representative(s): Lisa Osthues and Michael Glass 3. Title(s): Pretreatment Coordinator (Ms. Osthues) and ORC (Mr. Glass) 4. Last Inspection Date: 5/13/2022 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: ICIS CODING Main Program Permit Number INIC101012151414151 Are Milestone Dates Being Met? ❑ YES ❑ NO MM/DD/YY 1 8 I 31 128 1 Exp date 7. Current Number Of Significant Industrial Users S11tJs ? 0 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 ? 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? Exceeded limits for Pb (lead) in the months of March and April 2023. Due to closing of all industries discharging to POTW, the flow has altered and may have revealed higher lead concentrations POTW is in the process of trying to trace lead. The city divided the collection system into quadrants and conducted sampling at specific points. The POTW will conduct additional monitoring to try and locate the source. It is believed illegal dumping (by non-SIU) is occurring containing lead waste. One sample location in CS system has inconsistent readings (to below POL to exceeding limit). 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 SNC for either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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 ❑ YES ® NO Limits: 0 Reporting: 0 blished: na None [-]YES ® NO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO *Note: PQLs are currently being updated and reflected in LTMP recently submitted. Currently analyzing at lower PQLs. 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? EYES ❑ NO Is Table Adequate? EYES ❑ 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 ❑ NO If yes, which ones? Eliminated: na Added: Future addition of PFAS,1, 4-dioxane and silver (Ag) **LTMP recently submitted 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in their files_ comnlete with sunnorting documents and conv of PERCS Annroval 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) 6/6/2023 ® Yes ❑ No 8/16/2017 ® Yes ❑ No Tba*** Industrial Waste Survey IWS 6/6/2023 ® Yes ❑ No 5/25/2018 ® Yes ❑ No Tba*** Sewer Use Ordinance SUO 1/3/2013 ® Yes ❑ No 2/4/2013 ® Yes ❑ No -- Enforcement Response Plan (ERP) 1 5/15/2020 ® Yes ❑ No 1 8/11/2020 ® Yes ❑ No I -- Long Term Monitoring Plan (LTMP) 1 9/1/2023 ® Yes ❑ No 1 10/10/2011 ® Yes ❑ No Tba*** ***Recently submitted and awaiting approval. Next due date to be determined once approved INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Deep River Dyeing 2. 3. 30. IUP Number 1 0002 31. Does File Contain Current Permit? PERMIT TERMINATED ® Yes ❑ No El Yes ❑ No ❑Yes ❑ No 32. Permit Expiration Date INDUSTRY CLOSED / PERMIT ENDED -4 11/30/2023 33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A NA 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? I ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? a. ❑Yes ENo a. ❑Yes ❑No a. ❑Yes El b. If No, is One Needed? See Inspection Form from POTW b. ❑Yes ENo b. []Yes ❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan TOMP ? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes []No a. []Yes ❑No a. ❑Yes []No b. All Issues Resolved? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No ElYes ElNo ❑Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ®Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its Yes❑NoEN/A P ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required b IUP, includingflow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ❑Yes❑No[D ❑Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑No[D ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Re ortin Non-Com liance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. If applicable, Did POTW resample within 30 days of becoming aware of SIU limit violations in the POTW's sampling of the SIU? c.❑Yes❑No®N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP OVs, Penalties, timing, etc.)? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 50. a. Does the 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 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No FILE REVIEW COMMENTS: Files are in good order. For 2023, there will be no industries to monitor and inspect, however POTW wants to keep PT program active for future industries that may begin operations in the area. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY 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: Requirements: Recommendations: NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Tricia Lowery & Jesse Barnes DATE: 9/7/2023 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3