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Home My WebLink AboutNC0025909_Pretreatment Compliance Inspection Report_20230925 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. September 25, 2023 Doug Barrick Town of Rutherfordton Email: dbarrick@rutherfordton.net SUBJECT: Pretreatment Compliance Inspection Report Rutherfordton WWTP NPDES WW Permit No. NC0025909 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection (PCI) of the Town of Rutherfordton’s Pretreatment Program on 9/18/2023. The PCI 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 PCI form. 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: Compliance Inspection Report (BIMS), PCI Form Ec: Laserfiche Nadine Blackwell (Pretreatment Coordinator, Veolia) Phillip Reynolds (WWTP ORC, Veolia) DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA 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 NC0025909 23/09/18 P 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) Rutherfordton WWTP NC Hwy 221 Rutherfordton NC 28139 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:15AM 23/09/18 22/12/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Nadine J Blackwell/ORC/336-766-0270/ Other Facility Data 11:30AM 23/09/18 27/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Doug Barrick,129 N Main St Rutherfordton NC 28139/Town Manager/828-287-3520/Contacted 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 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: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA 9/22/2023 9/22/2023 9/22/2023 9/25/2023 NPDES yr/mo/day 23/09/18 Inspection Type P3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Rachel Rose, and Mara Chamlee, with the Asheville Regional Office, conducted a Pretreatment Compliance Inspection (PCI) of the Town of Rutherfordton's Pretreatment Program on September 18, 2023. Nadine Blackwell (Pretreatment Coordinator) and Phillip Reynolds (WWTP ORC) were present during the inspection. Overall, the program appears to be in compliance with Federal and State Pretreatment requirements. The Rutherfordton Pretreatment Program has one Significant Industrial User (SIU), which is a Categorical Industrial User (CIU), Aalied Die Cast. Paperwork was readily accessible and organized. See the attached PCI form for file review comments and recommendations. NC0025909 17 (Cont.) Page#2 DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Rutherfordton WWTP 2. Control Authority Representative(s): Nadine Blackwell and Phillip Reynolds 3. Title(s): Pretreatment Coordinator and ORC 4. Last Inspection Date: 01/04/22 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 | N | C | 0 | 0 | 2 | 5 | 9 | 0 | 9 | | 09 | 18 | 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? 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)? 1 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? The facility had one NOV for the daily minimum of dissolved oxygen not being reached. The facility did not have any issues after November 2022. YES NO 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? YES NO 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) SNC for Limits: 0 SNC for Reporting: 0 Not Published: 0 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? 0 21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? YES NO 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 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: Added:_______________________ DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 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) 07/15/20 Yes No Not approved yet Yes No 2025 Industrial Waste Survey (IWS) 04/15/19 Yes No 07/01/19 Yes No 05/01/24 Sewer Use Ordinance (SUO) 04/15/19 Yes No 07/01/19 Yes No N/A Enforcement Response Plan (ERP) 02/13/20 Yes No 02/14/20 Yes No N/A Short Term Monitoring Plan (STMP) 04/15/19 Yes No 07/01/19 Yes No N/A __________Short term?_______________________________________________________________________________________________ INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Aalied Die Cast 2. 3. 30. IUP Number 0003 31. Does File Contain Current Permit? Yes No Yes No Yes No 32. Permit Expiration Date 12/31/23 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 464.14 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No 36. a. Does the File Contain a 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 37. 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 38. a. Does File Contain Original Permit Review Letter from the 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 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? Yes No Yes No Yes No 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 Sampling as Required by IUP, including flow? Yes No N/A Yes No N/A Yes No N/A 41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports on time? Yes No N/A Yes No N/A Yes No N/A 42a. 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 42b. 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 43a. During the Most Recent Semi-Annual Period, Did the POTW Identify All Limits Non-Compliance from Both POTW and SIU Sampling? Yes No N/A Yes No Yes No 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/A Yes No N/A Yes No N/A 44. a. Was the 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 within 30 days of becoming aware of SIU limit violations in the POTW’s sampling of the 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 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 (NOVs, 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 DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 FILE REVIEW COMMENTS: The STMP File Review section was not filled out because STMP monitoring is not required until one year prior to updating the HWA. The HWA was submitted in July 2020 and has not been approved yet. Ms. Armeni (ARO Environmental Specialist II) reached out to the NPDES Municipal Permitting Unit – Pretreatment Section to determine when STMP monitoring should be started for the next HWA. Mr. Keyes McGee (NCDEQ Pretreatment Coordinator) indicated that the Town should proceed with STMP sampling in 2024 with HWA sub mission in 2025. Ms. Blackwell indicated that Aalied Die Cast typically does not discharge to the WWTP because they have a water recycling system. The last time they discharged was in January 2023 because they were conducting cooling tower repairs. Duri ng this time, all sampling was conducted, and permit limits were met. Ms. Blackwell also stated they periodically check the manhole where flow from Aalied Die Cast goes into the WWTP to verify that they are not discharging. When reviewing sampling data from Aalied Die Cast, it was noted that Antimony and Zinc reporting levels were above the recommended laboratory detection limits listed on their IUP. It is recommended to have Aalied Die Cast send a copy of their IUP to the lab they use for analyses. When reviewing the POTW sampling data, it was noted that the sampling results did not list any laboratory reporting levels, and it is recommended to send the lab a copy of the IUP. 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:________________________________________Title:_____________________________________________ Phone:__________________________________________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: DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4 OVERALL SUMMARY AND COMMENTS: Comments: Great job keeping paperwork very organized and readily available. Requirements: None. Recommendations: Have Aalied Die Cast send their lab their IUP, and send their IUP to the POTW’s lab. NOD: YES NO NOV: YES NO QNCR: YES NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Lauren Armeni, Rachel Rose, and Mara Chamlee DATE: 09/18/23 DocuSign Envelope ID: 5ED44EC1-BA61-4E8F-8CC8-262485D04CFA