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HomeMy WebLinkAboutNC0066516_Pretreatment Compliance Inspection_20231120DocuSign Envelope ID: 041BD094-E452-48BF-B6E9-D23A5DA3CE40 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Mr. Michael Wagner Public Utilities Director Town of Fuquay-Varina 134 N. Main Street Fuquay-Varina, NC 27526 NORTH CAROLINA Environmental Quality November 20, 2023 Subject: Pretreatment Compliance Inspection Town of Fuquay-Varina, Terrible Creek WWTP NPDES Permit No. NCO066516 Wake County Dear Mr. Wagner: On September 15, 2023, Cheng Zhang of the Raleigh Regional Office conducted an compliance inspection of Town of Fuquay-Varina's pretreatment program. The assistance given by Ms. Heather Adams, the Assistant Utilities Director, Mr. Chris Grimes, the Public Utilities Operations Manager, and Mr. Adam Stephenson, the Wastewater Treatment Plant Supervisor, was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: 1. The Town has one Significant Industrial User (SIU), which is also a Categorical Industrial User (CIU). It was noted that the SIU was not in Significant Non -Compliance (SNC) during the two most recent semi-annual periods. 2. The pretreatment inspection file review included John Deere Turf Care (Permit No. 0003). The files needed for review were available for inspection, containing all the required elements. In the first half of 2023, the SIU did not have any limit violations. It was noted that the SIU only reported flow when samples were taken, the IUP requires the SIU to record flow for each batch of discharge, please let the industry know that they need to record flow from each batch of discharge and submit monthly flow report to the Town. 3. A review of the files containing the pretreatment program elements was conducted. All files were available, up to date, and well organized. Long Term Monitoring Plan (LTMP) update was submitted on September 11, 2023, and is in review by the Division. 4. Long Term Monitoring Plan (LTMP) data were reviewed during the inspection. It was noted that all locations were sampled with required frequencies and all samples analyzed with required detection levels since the last inspection. It was noted that LTMP effluent data had not been reported on Discharge Monitoring Report. Effluent data from the LTMP shall be reported on the DMRs (as required by Parts II.D and II.E.5. of the NPDES Permit). [15A NCAC 02H .0903(b)(16), .0906(b)(3) and .09051. North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609 NORTH CAROLINA ^ 919.791.4200 n�,Mo E,Amnm W1 Q­1K, DocuSign Envelope ID: 041BD094-E452-48BF-B6E9-D23A5DA3CE40 Please respond in writing within 30 days of receipt of this letter regarding Items 2 and 4. If you have any questions or comments, please call Cheng Zhang at (919) 791-4200 (or email: cheng. zhang@deq.nc. gov). Sincerely, DocuSigned by: Vaun t,SSa f. 62916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Attachments: Pretreatment Compliance Inspection Cc: Laserfiche Chris Grimes, Town of Fuquay-Varina (electronic copy only) D � ��� North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CAROLINA ��` 919.707.9000 nnpn .mo EnWromm�nfal nual DocuSign Envelope ID: 041BD094-E452-48BF-B6E9-D23A5DA3CE40 r C'. 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: Town of Fuguay Varina 2. Control Authority Representative(s): Heather Adams, Chris Grimes, and Adam Stephenson 3. Title(s): Assistant Utilities Director, Utilities Operations Manager, WWTP Supervisor 4. Last Inspection Date: September 28, 2021 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 TTO certification?? Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ICIS CODING Main Program Permit Number MM/DD/YY I N I C 1 0 10 16161511161 1091151231 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? 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 Put 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: None Reporting: None dished: None None [—]YES ® NO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO ❑N/A 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO ❑ N/A 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ❑ YES ® NO Is Table Adequate? ® N/A 25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ❑ YES ®NO 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: NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 DocuSign Envelope ID: 041BD094-E452-48BF-B6E9-D23A5DA3CE40 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) 8/31/2020 ® Yes ❑ No 6/23/2022 ® Yes ❑ No 8/31/2026 Industrial Waste Survey (IWS) 10/29/2021 ® Yes ❑ No 4/1/2022 ® Yes ❑ No 4/4/2027 Sewer Use Ordinance (SUO) 1/29/2014 ® Yes ❑ No 5/9/2014 ® Yes ❑ No Enforcement Response Plan (ERP) 1 6/10/2020 ® Yes ❑ No 9/2/2020 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 1 9/11/2022 ® Yes ❑ No 3/6/2019 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. John Deere Turf Care 2. 3. 30. IUP Number 0003 31. Does File Contain Current Permit? ® Yes ❑ No 32. Permit Expiration Date 3/31/2024 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? a. ®Yes ❑No b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ®Yes❑No❑N/A Organic Management Plan TOMP ? 38. a. Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No b. All Issues Resolved? b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete 7��o®N/A its Sampling as Required b IUP, includingflow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ❑Yes❑No®N/A 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its ❑Yes®No❑N/A Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ®Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes0No[9 IF file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑No®N/A production rates and/or flows as Required b IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑No®N/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑No®N/A All Reporting_Non-Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑No®N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.❑Yes❑No®N/A c. If applicable, Did POTW resample within 30 days of becoming aware c.❑Yes❑No®N/A of SIU limit violations in the POTW's sampling of the SIU? 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes❑No®N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A 50. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 DocuSign Envelope ID: 041BD094-E452-48BF-B6E9-D23A5DA3CE40 FILE REVIEW COMMENTS: 39 — The POTW will conduct its annual sampling in October 2023. 41— John Deere only reported flow on the day of quarterly sampling. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number 1. Industry Inspected: 2. Industry Address:_ 3. Type of Industry/Product: 4. Industry Contact: Title: MM/DD/YY 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: OVERALL SUMMARY AND COMMENTS: Comments: The program is well managed. Requirements: The POTW must report effluent LTMP data on DMR. The POTW needs to require John Deere to record flow of each batch discharge and submit flow report to the POTW monthly. Recommendations: None NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: ❑ Satisfactory ® Marginal ❑ Unsatisfactory PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 15, 2023 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3