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HomeMy WebLinkAboutNC0023736_Pretreatment_Audit_20220808DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director � SfNfa NORTH CAROL.INA Environmental Quality SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. August 8, 2022 Elisa R. Triplett, Wastewater Superintendent City of Lenoir Lower Creek WWTP E-mail: I rtriplett@CI. LENOIR. NC. US SUBJECT: Pretreatment Audit Gunpowder Creek WWTP& Lower Creek WWTP NPDES WW Permit No. NCO023736 Caldwell County Dear Permittee: The North Carolina Division of Water Resources conducted Pretreatment Audit of the Lenoir Pretreatment Program on 8/02/2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0023736. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "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. 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. ATTACHMENTS Ec: LF Sincerely, DocuSigned by: 082B1105A3CA418... Tim Heim, Environmental Engineer Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ D �� NorMCe Regicnepartrner 200U 5, Highway QeaI 5wanna-Noah rResources -/ Asheville Regional0115ce1209013�5. Highway 701 Swannanoa, Noah ('srolfna 28778 828.296 Me DocuSign Envelope ID: 678408AO-5EFC-4ECA-B37C-6CCB87BCACE7 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN 2 u 3 I NC0023736 111 121 22/08/02 I17 18 LC] I 19 I s I 201 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, I 73 � I 74 79 I I I I I I I80 70 I I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 09:OOAM 22/08/02 21/04/01 Gunpowder Creek WWTP 450 Pine Mtn Rd Exit Time/Date Permit Expiration Date Hudson NC 28638 01:OOPM 22/08/02 26/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Elisa Robbins Triplett/ORC/828-757-2198/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Elisa Robbins Triplett,PO Box 958 Lenoir NC 286450958H828-757-4462/ 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/ 8/8/2022 ocuSigned by:E�D 4t101UAA C1UN4 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Q Q v/"/ DocuSigned by: 2022 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 NPDES yr/mo/day Inspection Type (Cont.) NCO023736 I11 12I 22/08/02 117 18 1,1 IUI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Tim Heim of the Asheville Regional Office performed a Pretreatment Audit on August 2nd, 2022. Lisa Triplett (Pretreatment Coordinator), Donnie Hawkins (ORC), and Haden Land (Pretreatment Sampler) assisted with the inspection and with records and sampling results review. An inspection of the Beocare Facility was performed with the Lenoir Pretreatment Staff. The program appears compliant. The Pretreatment Coordinator reports good communications and working relationships with all Us in the program. See attached NC DEQ Pretreatment Compliance Inspection form for details. Page# DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 Permit: NC0023736 Owner -Facility: Gunpowder Creek WWTP Inspection Date: 08/02/2022 Inspection Type: Pretreatment Audit Yes No NA NE Page# DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 NORTH CAROLINA DIVISION OF WATER RESOURCES 1%�" PRETREATMENT AUDIT REPORT Water Resources ENVIRONMENTAL QUALITY Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: City of Lenoir: Gunpowder Creek & Lower Creek WWTPs 2. Control Authority Representative(s) & Titles: Lisa Triplett (Pretreatment Coordinator), Donnie Hawkins (ORC), Haden Land (Pretreatment Sampler) 3. Address of POTW: Mailing 1905 Broadland Road City Lenoir Zip Code 28645 Phone Number 828-757-4462 Fax Number E-Mail lrtriy1ettna ci.lenoir.nc.us 5. Audit Date 08/02/2022 6. Last Inspection Date: 01/09/2019 Inspection Type: ❑ PCI ® Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No If No, Explain. NA 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No If Yes, Explain. NA 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 INIC101012 13 17 13 16 1 MM/DD/YY I08IO2I22I 10. ................................................................. Current Number of Significant Industrial Users(SIUs)?............................................................................................... 5 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? 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)?............................................................................................ 3 19. Number of CIUs in SNC? 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 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 Headworks Analysis (HWA) 3/31/2022 x Yes ❑ No 11/30/2018 x Yes ❑ No Industrial Waste Survey IWS 08/08/2018 x Yes ❑ No 11/08/2012 x Yes ❑ No Sewer Use Ordinance SUO 10/11/12 x Yes ❑ No 10/05/15 x Yes ❑ No Enforcement Response Plan (ERP) 08/20/2015 x Yes ❑ No 1 12/20/15 x Yes ❑ No Long Term Monitoring Plan (LTMP) 10/21/04 x Yes ❑ No 10/29/04 x Yes ❑ No 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. NA 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 12/04/2012 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. (Performed during inspection) 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=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining Ideally, a program of this size would have a dedicated POTW's Pretreatment Program ❑S ®M ❑U Pretreatment Coordinator. Access to POTW Vehicles for Sampling, Inspections, and ®S ❑M ❑U Emergencies 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 It is highly suggested that staff attend the annual NC Regional Workshops, Etc.) ®S ❑M ❑U Pretreatment Conference on a yearly basis. Computer Equipment (Hardware and Software) ®S ❑M Flu 30. Does the POTW have an adequate data management system to run the pretrcatmcnt program? ® Yes ❑ No NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 Explain Yes or No. Spreadsheets 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Cost is recovered through penalties associated with Pretreatment violations. It is recommended that the program consult with other municipalities about the potential for additional cost recovery options. 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? 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 ® NA Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Chamber of Commerce, communication with other city officials, applications for new taps. 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?) IWS Form, Interviews and Inspections, Nature of Business, Flow Request. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ❑Yes ®No If Yes, How many are there? Please list each site and how it is permitted, if applicable. 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) Septage Haulers Agreement, 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: 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.) 46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No If yes, what percentage of each parameter —20% recommended, working with McGill on this. 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) Historical Use 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. As directed by DEQ Pretreatment program. NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 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, reporting requirements, and permit conditions, as well as for SNC. All of the above as appropriate. 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? Potential for release and nature of the industry. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Potential for release and nature of the industry, discussion with IUs. 56. How does the POTW decide where the sample point for an SILT should be located? Representative of effluent being discharged to sewer. 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SILT 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. 24-hour composite, random unannounced inspections 58. Who performs sample analysis for the POTW for Metals MeriTech Conventional Parameters In House Lab Organics MeriTech 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Standard industry practice COC SOP. 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 Monitoring? ® YES ❑ NO 60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO 60d. All LTMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself! 60e. 60f. If NO to any above, list violations 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? McGill Engineers Phone 828 252--0575 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 disposal)? ❑ Yes ® No Explain. 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 4 DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Beocare 2. Lenoir Mirror 11 3. Excela Pharma (Augusta) 67. IUP Number 0008 0007 0020 68. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 69. Permit Expiration Date 12/21/2022 12/21/2022 12/21/2022 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A NA 413 439 71. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No to Permit Issue Date? 72. Does File Contain Inspection Completed Within Last Calendar Year? ® Yes ❑ No ® Yes ❑ NoI ® Yes ❑ No 73. a. Does File Contain Slug/Spill Control Plan? a. ®Yes [-]No a. ®Yes ❑No a. ®Yes ❑No b. If No, is One Needed? See Inspection Form from POTW) b. []Yes []No b. ❑Yes ❑No I b. []Yes ❑No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑No®N/A ®Yes❑No❑N/A ❑Yes❑NOON/A Organic Management Plan (TOMP)? 75. a. Does File Contain Original Permit Review Letter from Division? a. ®Yes [-]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 76. During Most Recent Semi -Annual Period, Did POTW Complete its ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No Sampling as Required by IUP, includingFlow? 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ N=ol ® Yes ❑ No ® Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its ❑Yes❑No®N/A ❑Yes❑NoON/A ❑Yes❑No®N/A Sampling as Required b IUP, including Flow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on ❑Yes0No[9 ❑Yes❑No®N/A ❑Yes❑No®N/A time? 80a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoON/A file include process/dilution flows as Required b IUP? 80b. For categorical IUs with Production based limits, does file include ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A production rates and/or flows as Required by IUP? 81. During Most Recent Semi -Annual Period, Did POTW Identify All ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Limits Non -Compliance from Both POTW and SIU Sampling? No Violations No Violations No Violations 82. During Most Recent Semi -Annual Period, Did POTW Identify All ❑Yes❑NOON/A ❑Yes❑NoON/A ❑Yes❑No®N/A Re ortin Non-Com liance from SIU Sampling? 83. a. Was POTW Notified by SILT (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 and obtain results within 30 days of c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A becoming aware of SIU limit violations in the POTW's sampling of SIU? 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 ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? 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? a.❑Yes❑No®N/A I a.❑Yes❑No®N/A a.❑Yes❑No®N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested Yes ® No ❑Yes ®!o7 es ® No Information For You? 1[❑ FILE REVIEW COMMENTS: None. NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY I N I C 1 0 1 0 12 1 3 1 7 1 3 1 6 108 1 02 1 22 1 1. Industry Inspected: Beocare 2. Industry Address: 1905 International Drive, Hudson, NC 3. Type of Industry/Product: Medical undergarments with dye process 4. Industry Contact: JR McCormick Title: CEO/ Ovs Manager Phone: 828-449-6082 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: A complete inspection was conducted as part of the PCA. The IU and Lenoir WWTP staff are working together to identify an unknown source of lint -like material that periodically accumulates in a nearby pump station. Audit SUMMARY AND COMMENTS: Audit Comments: All components evaluated were satisfactory. Requirements: ERPs were sent to all the IUs the day of the Audit as requested. Recommendations: • Appoint a Pretreatment Coordinator as a new and distinct position from the other roles currently being performed by the WWTP Superintendent. • It is highly suggested that staff attend the annual NC Pretreatment Conference on a yearly basis. This provides valuable training and a reasonable cost. • Cost is recovered through penalties associated with Pretreatment violations. It is recommended that the program consult with other municipalities about the potential for additional cost recovery options. NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ D S'g d by Audit COMPLETED BY: 2�g,o„��.,,..,,o DATE: 08/02/2022 Tim Heim, Asheville Regional Office NC DWR Pretreatment Audit Form Revised: December 2016 Page 6