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HomeMy WebLinkAboutNC0086550_Pretreatment Audit_20230815ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Edwin Fields Town of Fairmont PO Box 248 Fairmont, NC 28340-0248 NORTH CAROLINA Environmental Quality August 15, 2023 SUBJECT: Pretreatment Audit Fairmont Regional WWTP NPDES Permit No. NCO086550 Robeson County Dear Mr. Fields: A Pretreatment Audit of the Town of Fairmont's Pretreatment Program was conducted by Sharon Moran from this office on July 20th, 2023. The purpose of this audit 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 Audit Form from the inspection conducted on July 201h, 2023. The Pretreatment Audit was conducted by Sharon Moran, Environmental Specialist of the Fayetteville Regional Office with Edwin "Tommy" Fields, ORC of Fairmont, and Nadine Blackwell, Pretreatment Consultant with Veolia. Fairmont is currently a 1.75 MGD permitted facility and has one (1) Significant Industrial User, Harger, which is a 468 Categorical Industrial User. One permit file was reviewed: Harger Inc. Additionally, a site visit was conducted at Harger Inc. to observe Ms. Blackwell and Mr. Fields inspecting the industry. This inspection included Sharon Moran (FRO), Edwin Fields (POTW), Nadine Blackwell (Pretreatment Consultant with Veolia), Kurt Holmes (Plant Manager at Harger Inc), and David Ransom (Harger Inc, in training to take over future inspections). The findings and comments noted during this inspection are provided in the enclosed copy of the audit report. Please respond in writing to this office within 30 days of your receipt of this letter regarding your plans or measures to be taken to address the following issues: 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 - oeuaMemofEnvi—memaiauai\ 910.433.3300 This PT audit report indicated that the Fairmont Pretreatment Program did not meet all reporting requirements as outlined in 40 CFR 122.41(I)(4), namely that sampling results from LTMP testing were not submitted in the eDMR for the corresponding month. 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, DocuSigned byw�1.N}'�I,�'- I E4E1A9691 DB248E... 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 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH nt oROUNn Department tEnvironmental Qua] 919.707.9000 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 NC0086550 I11 121 23/07/20 I17 18 L� ] 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 70I 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 23/07/20 22/12/01 Fairmont Regional WWTP Off US Hwy 74 Exit Time/Date Permit Expiration Date Fairmont NC 28340 12:30PM 23/07/20 27/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Edwin Thomas Fields/ORC/910-734-1671/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Johnny J Britt,PO Box 248 Fairmont NC 283400248/Superintendent/910-628-0064/ 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 Sharon Moran Docusigned by: DWR/FRO WQ/910-433-3300/ 8/15/2023 Lvbt& Auraiv, E�2BE17E499D6943D... Signature of Mana meRRVjRTt0Yewer Agency/Office/Phone and Fax Numbers Date Mark Brantley A"oy� W tvau1gR/Division of Water Quality/910-433-3300 Ext.727/ 8/15/2023 E4PA9691 DB248E... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO086550 I11 12I 23/07/20 117 18 1,1 lul (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Enclosed, please find a copy of the Pretreatment Audit Form from the inspection conducted on July 20th, 2023. The Pretreatment Audit was conducted by Sharon Moran, Environmental Specialist, of the Fayetteville Regional Office with Edwin "Tommy" Fields, ORC of Fairmont, and Nadine Blackwell, Pretreatment Consultant with Veolia. Fairmont is currently a 1.75 MGD permitted facility and has one (1) Significant Industrial User, Harger, which is a 468 CIU. One permit file was reviewed: Harger. Additionally, a site visit was conducted at Harger to observe Ms. Blackwell and Mr. Fields inspecting the industry. This inspection included Sharon Moran (FRO), Edwin Fields (POTW), Nadine Blackwell (Pretreatment Consultant with Veolia), Kurt Holmes (Plant Manager at Harger Inc), and David Ransom (Harger Inc, in training to take over future inspections). Page# Permit: NC0086550 Inspection Date: 07/20/2023 Owner -Facility: Fairmont Regional WWTP Inspection Type: Pretreatment Audit Yes No NA NE Page# NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Water Resources ENVIRONMENTAL QUALITY Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Town of Fairmont 2. Control Authority Representative(s): Nadine Blackwell (Pretreatment Consultant with Veolia), Edwin T. Fields 3. Title(s): Pretreatment Coordinator, ORC 4. Address of POTW: Mailing P.O. Box 248 City Fairmont Zip Code 28340 Phone Number (910) 734-1671 Fax Number E-Mail 5. Audit Date 07/20/2023 6. Last Inspection Date: 07/26/2021 Inspection Type: ® PCI ❑ Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No If No, Explain. 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No If Yes, Explain. 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 INIC101OI8 16 Is Is In MM/DD/YY 1 07 1 20 123 10: Current Number of Significant Industrial Users (SIUs)? .11....Num..ber...of..SIUs. ..with.No I.UP, or with an Expired IUP? ...................................... 12: Number of SIUs Not Inspected by POTW in Last Calendar Year? ........................................................................................................ 13 : Number of SIUs Not Sampled by POTW in Last Calendar Year? .................................................................................................. 14: Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods? 15: Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? ...................................................................... 16. Number of SIUs in SNC with Pretreatment Schedule? ................................................................................................................................................................................................... . 17. Number of SIUs on Schedules? ................................................................................................................................................................................................... . 18: Current Number of Categorical Industrial Users (CIUs)? 19. Number of CIUs in SNC? ................................................................................................................................................................................................... . 1 0 0 0 0 0 0 0 1 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 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 Date Next Due, If Applicable Headworks Analysis (HWA) 11/17/2021 ® Yes ❑ No Pending ❑ Yes ❑ No Industrial Waste Survey (IWS) 07/02/2020 ® Yes ❑ No 09/29/2020 ® Yes ❑ No 07/01/2025 Sewer Use Ordinance (SUO) 02/25/2013 ® Yes ❑ No 03/21/2013 ® Yes ❑ No Enforcement Response Plan (ERP) 09/03/2010 ® Yes ❑ No 12/01/2010 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 11/13/2019 ® Yes ❑ No 01/03/2020 ® 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. Cerro Gordo, Fairbluff, Proctorville, Borden 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 02/19/2013 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. 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 N/A Resources 29. Please Rate the Followine: S=Satisfactory M=Mareinal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program ®S ❑M ❑U 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 Regional Workshops, Etc.) ®S ❑M ❑U Computer Equipment (Hardware and Software) ®S ❑M ❑U NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Uses Hachwims database 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Town bills industry for consultant fees as well as all sampling costs. 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? They will be told to make an appointment, asked to justify their need, and the public is allowed to access non -confidential information. 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? Only trade secrets would be allowed to be identified as confidential information, the information would be sealed and labelled as confidential. 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 Town hearing/publication 37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ®NA Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Town manager, Point of Contact at industry 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?) Proposed discharge against HWA, Fed Regulations for categorical, filling out an IWS. 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) N/A 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: 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.) N/A 46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No If yes, what percentage of each parameter?: _10%_ 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) Categorical parameters, NPDES Pollutants of Concern, HWA Pollutants of Concern NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. How much buffer is in reserve, how much impact it would have on the plant, NPDES limits 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. Severity of violation, escalation chart 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? Chemical storage, propensity for spillage 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Notification to POTW, procedure for clean-up and containment 56. How does the POTW decide where the sample point for an SILT should be located? Below treatment processes, safe and accessible location 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU 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. Established at beginning with POTW 58. Who performs sample analysis for the POTW for Metals TBL Conventional Parameters TBL Organics TBL 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Use TBL's COC, verify information on COC is correct and sign/date 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/STMP Monitoring? ®YES ❑ NO 60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®YES ❑ NO Is Table Adequate? ❑ YES ❑ NO 60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ❑ YES ® NO Division Inspector, verify yourself. 60e. If NO to any above, list violations _LTMP sampling data was not recorded and submitted on appropriate eDMR 60f. 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? Nadine Blackwell Phone (336) 766-0270 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 05 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. Not necessary NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1Harger 2. 3. 67. IUP Number 001 68. Does File Contain Current Permit? ® Yes ❑ NoI ❑ Yes ❑ NoI ❑ Yes ❑ No 69. Permit Expiration Date 2/28/2027 70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A 468 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 ❑ No ❑ 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 b. []Yes []No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic YesENo❑N/A P11 ❑Yes❑No❑N/A ❑Yes❑No❑N/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]1 ❑ Yes ❑ No ❑ Yes ❑ No Sampling as Required by IUP, including Flow? 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No 11 ❑ Yes ❑ No ❑ Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its EYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, including Flow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on ❑YesENo❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A time? 80a. 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? 80b. For categorical IUs with Production based limits, does file include ❑Yes❑NoEN/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 s ElNo 77� El Yes ❑ No El Yes El No Limits Non -Compliance from Both POTW and SIU Sampling? 82. During Most Recent Semi -Annual Period, Did POTW Identify All EYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Re ortin Non -Compliance from SIU Sampling? 83. a. Was 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 and obtain results within 30 days of c.❑Yes❑NoEN/A becomingaware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A 84. During Most Recent Semi -Annual Period, Was SIU in SNC? ❑ Yes® No 11 ❑ Yes ❑ No 11 ❑ Yes ❑ No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as EYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Specified in POTW's ERP OVs, Penalties, timing, etc.)? 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 88. a. Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑NoEN/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑ Yes ® No ❑ Yes ❑ ❑ Yes ❑ No Information For You? !j FILE REVIEW COMMENTS: NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY N I C 1 0 1 0 1 8 16 15 15 10 07 120 123 1. Industry Inspected: Harger Inc 2. Industry Address: 12779 Hwy 130E Business Fairmont NC 3. Type of Industry/Product: Process Washdown from metal finishing (468) 4. Industry Contact: Kurt Holmes Title: Plant Manager Phone: (847) 543-5074 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: Audit SUMMARY AND COMMENTS: Audit Comments: Requirements: Amended eDMR must be submitted to include LTMP sampling data. As of 8/14/2023, Mr. Fields has submitted the amended eDMR to include LTMP sampling. Recommendations: NOD: ❑ Yes ❑ No NOV: ❑ Yes ❑ No QNCR: [—]Yes ❑ No POTW Rating: Satisfactory ❑ Marginal ® Unsatisfactory ❑ DocuSigned by: S6,,bv. M.braiv. 8/15/2023 Audit COMPLETED BY: DATE: 2BE17E499D6943D... Sharon Moran, Fayetteville Regional Office NC DWR Pretreatment Audit Form Revised: December 2016 Page 6