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NC0021709_Compliance Evaluation Inspection_20151015
North Carolina Department of Environmental Quality Pat McCrory Donald R. van der Vaart Governor Secretary October 15, 2015 Mr. Tim Church, Water Resources Director Town of Jefferson P.O. Box 67 RECEIVEDMENR/DWR Jefferson,NC 28640 OCT 2 2 2015 Water Quality SUBJECT: Pretreatment Compliance Inspection(PCI) Permitting Sectior Town of Jefferson NPDES 4 NCO021709 Ashe County Dear Mr. Church: On October 9, 2015 George Smith, of this office, performed a PCI of the Town's pretreatment program. Mr. Tim Church was present. The purpose of this inspection was to determine the effectiveness of the Town's pretreatment program, which included: reviewing the files, POTW plant performance, sampling and compliance judgment program, and adherence to the enforcement response plan(ERP). Background The Town operates a 0.600-MGD facility, and,has one significant industrial user, which is categorically i.regulated: American Emergency Vehicles (AEV).per CFR 433( metal finishing). POTW Interview There were no limit violations related to pretreatment from January 2015 through July 2015. Pretreatment Program Elements Review The Headworks Analysis (HWA) is due April 1, 2017. The Industrial Waste Survey (IWS) is due May 1, 2019. The Sewer Use Ordinance (SUO) was approved on November 7, 2012. The Enforcement Response Plan (ERP) was approved on April 7, 2003. The Short Term Monitoring Plan (STMP) was approved on January 21, 2011. 450 W Hanes Mill Rd.,Suite 300,Winston-Salem,NC 27105 Phone:336-776-9800\Internet:www.ncdenr.gov An Equal Opportunity\Affirmative Action Employer—Made in part by recycled paper STMP File Review The Short Term Monitoring Plan(STMP)was updated to meet PERCS requirement to perform one quarterly sample for four consecutive quarters prior to the HWA. Industrial User Permit (IUP) File Review American Emergency Vehicles (#004)permit expires on July 31, 2017. This is a categorical industry under CFR 433. The monitoring and compliance/judgment were satisfactory. The chain of custody and lab reporting are in excellent order. Action Items 1. The pretreatment annual report for the period of January—December 2015 is due on March 1, 2016. 2. Please remember to perform STMP sampling once each quarter during 2016. The pretreatment compliance inspection is satisfactory. The program is being implemented in an excellent manner. If you have any questions, please contact George Smith or me at(336) 776-9800. Sincerely, a W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources,NCDEQ cc: PERCS Unit—Monti Hassan WSRO Files y '4 NORTH CAROLINA DIVISION OF WATER QUALITY PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION (Complete Prior To PCI• Review Program Info Database Sheet6)1 1. Control Authority(POTW)Name: 2. Control Authority Representative(s): cilurc� 1 3. Title(s): n-1 v°c'p's D tri 4. Last Inspection Date: Inspection Type(Check One): [I PCI [9-'A—udit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? E YES ❑ NO 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES [FIGO Order Type,Number, Parameters: hr%7 Are Milestone Dates Being Met? -] ❑ h`O PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type N l I N_I C 1 0 1 1 2-1 1 1 71-!1 1 1 ' 1 7 11�O 1 P l L-5-1 L-1-1 (DTIA) (TYPI) (INSP) (FACC) 7. Current Number Of Significant Industrial Users(SNs)? SNS 8. Current Number Of Categorical Industrial Users(CIUs)? CIUS 9. Number of SNs Not Inspected By POTW in the Last Calendar Year? O 10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? O 11.Enter the Higher Number of 9 or 10 0 NOIN 12.Number of SNs With No IUP, or With an Expired IUP 0 NOCM 13.Number of SNs in SNC for Either Reporting or Limits Violations During Either of the Last 2 O Semi-Annual Periods(Total Number of SIUs in SNC) PSNC 14.Number of SNs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods O MSNC 15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods SNPS 16.Number of SNs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods POTW INTERVIEW 17. Since the Last PCI,has the POTW had any NPDES Limits Violations? YYES ❑ NO If Yes,What are the Parameters and How are these Problems Being Addressed? arc ,w1Y f-11,1 n-cE rw la-4 18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ❑ YES O 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 Limits: either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting: Public Notice?(May refer to PAR if Excessive SNs in SNC) Not Published: 20. Which Industries are on Compliance Schedules or Orders?For all SNs on an Order,Has a Signed Copy of the Order been sent to the Division? N v n' 21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes, Which ❑ YES 1 O Ones? LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? �ES ❑ NO 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? 0,76, ❑ NO 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? [YES ❑ NO Is Tp.le Adequate? uES ❑ NO 25. All LTMP/STMP effluent data reported on Discharge Monitoring Report'? E9 YES ❑ NO DWQ inspector, please verify yourself! 26. if NO to 23 -26, list violations ti 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/S'rMP? ❑ YES —WNO If yes,which ones?Eliminated: Added: NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1 i- 28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verity POTW has copy of Program Element in their files,complete with su P rting documents and copy of PERCS Approval Letter,and dates consistent with Program Info: Program Element Last Submittal Last Approval Date Next Due, Date In file? Date In file If Applicable Headworks Analysis (HWA) ❑Yes ❑ No !), ❑9'Yes ❑ No 17 Industrial Waste Survey IWS ❑ Yes ❑ No 92- IV ayes ❑ No J'`I Sewer Use Ordinance(SUO) ❑ Yes ❑ No (l-7 - 112 0 Yes ❑ No Enforcement Response Plan ERP ❑ Yes ❑ No y-7 -0.3 'Yes ❑ No Long Term Monitoring Plan(LTMP) ❑ Yes ❑ No /_.11-!( i Yes ❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 N INSPECTION) 29. User Name IF I. ln,fycti„� ! / 2. 3. 30. IUP Number 31. Does File Contain Current Permit? D"Ns ❑ No ❑ Yes ❑- No ❑ Yes ❑ No 32. Permit Expiration Date 33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 34. Does File Contain Permit Application Completed Within One Year Prior © es ❑ No ❑ Yes ❑ No ❑Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? I ❑L'Yes ❑ No ❑ Yes ❑ Kol ❑ Yes ❑ No 36. a.Does the File Contain a Slug/Spill Control Plan? a. ❑Yes M<o_ a. ❑Yes ❑No a. Dyes ❑No b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes r o b. ❑Yes ❑No b. []Yes [:]No 37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic i es❑No❑N/A ❑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. v es[IN a.a. ❑Yes ❑No a. []Yes[:]NO All Issues Resolved? b.❑Yes❑Not7 A_ b❑Yes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi-Annual Period,Did the POTW Complete [des ❑ No ElYes El No El Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain-Of-Custody Forms? aes ❑ No IF-[:]Yes ❑ No ❑ Yes ❑ No 41. During the Most Recent Semi-Annual Period,Did the S1U Complete its es❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, including flow? 41 b. During the Most Recent Semi-Annual Period; Did SIU submit all reports es❑No❑ o❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No ; /A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file include process/dilution flows as Required by IUP? 42b. For categorical lUs with Production based limits,does file include ❑Yes❑No r /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 Pes-❑-No ❑ Yes ❑ No ❑ Yes ❑ No All Limits Non-Compliance from Both POTW and SIU Sampling? 4,11-' 43b. During the Most Recent Semi-Annual Period, Did the POTW Identify ❑Ycs❑No /A ❑Ycs❑No❑N/A ❑Ycs❑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❑NoUXfA 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❑NoUX/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[7N'!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 SN in SNC? [:] Yes ! o ❑ Yes ❑ No ❑ Yes ❑ No 47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑NoI�A ❑Yes❑No❑N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP(NOVs, Penalties,timing,etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEjN/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑N/A 49. Does The File Contain Proof Of Penalty Collection? 0Yes❑No65TA ❑Yes❑No❑N/A ❑Yes❑No❑N/A 50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑NoUN, a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b. Is SlU in Compliance with Order? b.❑Yes❑No[W'k' b.❑Yes❑No❑N/A b❑Yes❑No❑N/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ YesNo ElYes El No El Yes [-INo Requested Information For You? NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2 I FILE REVIEW COMMENTS: J 1n INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type/Inspector Fac.Type (DTIA) -(TYPI) (INSP) (FACC) 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 Eq to vale\? ❑ YES El 6. Did the POTW Contact Conductth'e Following Parts of the Industrial InspBctiThoroughly? Comments: A. Initial Interview' ❑ YES ❑ NO \ B. Plant Tour ❑ YES ❑ NO C. Pretreatment Tour ❑ YES ❑ NO D. Sampling Review ❑ YES ❑ NO E.,zExit Interview ❑ YES ❑ NO Industrial Inspection Comments: OVERALL SUMMARY AND COMMENTS: Comments: Requirements: Recommendations: NOD: ❑ YES L-11,1'NO NOV: ❑ YES [ANO QNCR: ❑ YES []�.NO POTW Rating: / Satisfactory t /Marginal / UnSatisfactory PCI COMPLETED BY: W t-..� ' : -tiJv��1✓ DATE: NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3 O s ;,,