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HomeMy WebLinkAboutNC0023957_Pretreatment Performance Compliance Inspection_20230901ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Tim Davis Fayetteville Public Works Commission PO Box 1089 Fayetteville, NC 28302-1089 NORTH CAROLINA Environmental Quality September 1, 2023 SUBJECT: Pretreatment Performance Compliance Inspection PWC Cross Creek WWTP NPDES Permit No. NCO023957 Cumberland County Dear Mr. Davis: A Pretreatment Compliance Inspection of PWC Fayetteville's Pretreatment Program was conducted by Sharon Moran from this office on August 9, 2023. The purpose of this inspection is to determine the effectiveness of the pretreatment program by reviewing various aspects of the program, which included files and records, industrial user inspections and monitoring data, data management procedures and adherence to the Enforcement Response Plan. Enclosed, please find a copy of the Pretreatment Compliance Inspection Form from the inspection conducted by Sharon Moran, Environmental Specialist, of the Fayetteville Regional Office and Tim Davis, Environmental Systems Protection Supervisor for PWC Fayetteville. PWC Cross Creek is currently a 25 MGD permitted facility and has eight (8) Significant Industrial Users; Goodyear, Unifirst, Cargill, Martin's Pork, Cumberland County Landfill, Purolator, Darling Ingredients, and Nitta Gelatin. Additionally, there are three (3) Categorical Industrial Users; Eaton Corporation, Hexion, and Dana Transport. One permit file was reviewed: Eaton Corporation. A site visit was conducted during this inspection at Martin's Pork in Falcon, NC. The site inspection included Sharon Moran of the Fayetteville Regional Office, Stevan Cox of PWC, and Beth Holmes, Owner of Martin's Pork to observe Mr. Cox inspecting the facility. This Pretreatment Compliance Inspection report indicated that PWC Cross Creek's Pretreatment Program did meet all requirements as outlined in 15A NCAC 2H .0900 for Pretreatment Programs. Mr. Davis is continuing to implement the Pretreatment Program in a consistent and professional manner. There were no significant issues or findings noted during the inspection and therefore, a D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301 NORTH CAROLINA - oeuaronemmemironmemaiauai\ p*O** 910.433.3300 response to this inspection report is not required. Thank you for your continued support of the North Carolina Pretreatment Program. If you should have any questions, please contact Sharon Moran at (910) 916-3489 or at sharon.moran@deq.nc.gov. Sincerely, E DocuSigned by E4EtA9691DB248E... Mark Brantley, Assistant Regional Supervisor Water Quality Regional Operations Section Fayetteville Regional Office Division of Water Resources, NCDEQ Cc: Upload to Laserfiche D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources vFayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301 NORTH CAROUNA 910.433.3300 oeaaresem of Eamm6eMal aual 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 1 2 u 3 I NC0023957 I11 121 23/08/09 I17 18I D I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, I 71 I 74 79 I I I I I I I80 701� I 711 L LJ L -1 I I 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 23/08/09 18/01/01 Cross Creek WWTP 601 N Eastern Blvd Exit Time/Date Permit Expiration Date Fayetteville NC 283015265 02:OOPM 23/08/09 22/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Mick J Noland,PO Box 1089 Fayetteville NC 283021089//910-223-4733/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Self -Monitoring Progran 0 Other 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 Sharon Moran Docusigned by: DWR/FRO WQ/910-433-3300/ 8/30/2023 LvDln, Alan. EsME17E499D6943D... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Mark Brantley DWR/Division of Water Quality/910-433-3300 Ext.727/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO023957 I11 12I 23/08/09 117 18 1 p I (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Enclosed, please find a copy of the Pretreatment Compliance Inspection Form from the inspection conducted on August 9th, 2023. The Pretreatment Compliance Inspection was conducted by Sharon Moran, Environmental Specialist, of the Fayetteville Regional Office and Tim Davis, Environmental Systems Protection Supervisor for Public Works Commission Fayetteville. PWC Cross Creek is currently a 25 MGD permitted facility and has eight (8) Significant Industrial Users; Goodyear, Unifirst, Cargill, Martin's Pork, Cumberland County Landfill, Purolator, Darling Ingredients, and Nitta Gelatin. Additionally, there are three (3) Categorical Industrial Users; Eaton Corporation, Hexion, and Dana Transport. One permit file was reviewed: Eaton Corporation. A site visit was conducted during this inspection at Martin's Pork in Falcon, NC. The site inspection was performed by Sharon Moran of the Fayetteville Regional Office, Stevan Cox of PWC, and Beth Holmes, Owner of Martin's Pork. This Pretreatment Compliance Inspection report indicated that PWC Cross Creek's Pretreatment Program did meet all requirements as outlined in 15A NCAC 2H .0900 for Pretreatment Programs. Mr. Davis is continuing to implement the Pretreatment Program in a consistent and professional manner. Page# Permit: NCO023957 Inspection Date: 08/09/2023 Other Comment: Owner -Facility: Cross Creek WWTP Inspection Type: Pretreatment Compliance Yes No NA NE Page# 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. 2. 3. 4. 5. 6. Control Authority (POTW) Name: Control Authority Representative(s): Title(s): Last Inspection Date PWC Crosscreek Tim Davis Environmental Systems Protection Supervisor 8/9/22 Inspection Type (Check One): ❑ PCI ® Audit Has Program Completed All Requirements from the Previous Inspection and Program Info Shcct(s)? ® YES ❑ NO Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO Order Type, Number, Parameters: ICIS CODING Main Program Permit Number I N I C 1 0 10 12 131915171 MM/DD/YY 1 081 09 1 23 Are Milestone Dates Being Met? ❑ YES ❑ NO 7. Current Number Of Significant Industrial Users SIUs ? 11 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? 2 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 ? 3 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 Pul 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 Slug of Ammonia from Darling, NOV and possible fines Limits: Mann and Hummel, Nitta Reporting: dished: ❑ 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 Division Inspector, please verify yourself! 26. If NO to 23 - 26, list violations NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 27 Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? If yes, which ones? Eliminated: Added: [—]YES ®NO 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) 05/30/2018 ® Yes ❑ No 07/12/2018 ® Yes ❑ No Industrial Waste Survey IWS 08/30/2018 ® Yes ❑ No 10/04/2018 ® Yes ❑ No 09/01/2023 Sewer Use Ordinance SUO 08/30/2018 ® Yes ❑ No 10/04/2018 ® Yes ❑ No 09/01/2023 Enforcement Response Plan (EPP) 03/06/2020 ® Yes ❑ No 1 5/11/2020 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 12/31/2020 ® Yes ❑ No 1 03/19/2021 ® Yes ❑ No INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION 29. User Name F. Eaton Corporation 2. 3. 30. IUP Number 2011RF 31. Does File Contain Current Permit? ®Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 32. Permit Expiration Date 12/31/2023 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 ❑ Ycs ❑ No ❑ Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ❑ Yes ElNo El Yes El No 36. a. Does the File Contain a 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 b. []Yes []No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Yes❑No❑N/A P ❑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. ®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 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No]1 ❑ Yes ❑ No ❑ Yes ❑ No its Sampling as Required b 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 EYes❑No❑N/A ❑Yes❑No❑N/A ❑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 [_57;;6TooN/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑No®N/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®N/A ❑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❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Rc 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 c.❑Yes❑No®N/A of SIU limit violations in the POTW's sampling of the SIU? c.❑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 11 ❑ Yes ❑ No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes❑No®N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A as Specified in the POTW's ERP OVs, Penalties, timing, etc.)? 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? a.❑Yes❑No®N/A jFb._1:3Yess[:1No[3N/A ❑Ye❑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 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? FILE REVIEW COMMENTS: INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY I N I C 1 0 1012 131915 17108109123 1 1. Industry Inspected: 2. Industry Address: 3. Type of Industry/Product: 4. Industry Contact: Martin's Pork 6657 King St Falcon, NC 28342 Slaughter/Pork Processor Beth Holmes ❑ Yes ® No ❑ Ycs ❑ No ❑ Yes ❑ No Title: Owner Phone: (910) 980-1501 Email: bdholmes@nc.rr.com 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: Be sure to complete Hg sampling on the same day as the other LTMP sampling, as required by approved LTMP plan. Requirements: Recommendations: NOD: ❑ YES ❑ NO NOV: ❑ YES ❑ NO QNCR: ❑ YES ❑ NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY TE: NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3