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HomeMy WebLinkAboutNC0021181_Inspection_20240304ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Jonathan Wilson, Public Works Director City of Belmont Post Office Box 431 Belmont, North Carolina 28012 NORTH CAROLINA Environmental Quality March 4, 2024 SUBJECT: Pretreatment Compliance Inspection City of Belmont NPDES Permit No. NCO021181 Gaston County Dear Mr. Wilson: Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Belmont's Pretreatment Program on February 27, 2024, by Mr. Wes Bell of this Office. Please advise the City's Pretreatment staff of our findings by forwarding a copy of the enclosed report. This Office would also like to thank the City's Pretreatment staff for the cooperation and assistance provided during the inspection. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell(a,deq.nc. gov. Sincerely, DocuSigned by: E Brandy Costner Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche !D Q� North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville. North Carolina 26115 704.663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION 1. Control Authority (POTW) Name: City of Belmont 2. Control Authority Representative(s): Jonathan Wilson, Tanya Carter and Ric La Mere 3. Title(s): Public Works Director, Wastewater Superintendent-ORC, Pretreatment Coordinator 4. Last Inspection Date: 1/26/23 Inspection Type: ® 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 ® NA ICIS CODING Main Program Permit Number MM/DD/YY NCO021181 02/27/24 7. Current Number Of Significant Industrial Users SIUs ? 2 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)? 0 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 fox either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fox Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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 See Comments [—]YES ® NO Limits: None Reporting: None flished: N/A N/A [—]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 26. If NO to 23 - 26, list violations: 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW Program Element Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 4/29/21 ® Yes ❑ No 4/15/20 ® Yes ❑ No In Review Industrial Waste Survey IWS 7/8/20 ® Yes ❑ No 10/12/20 ® Yes ❑ No N/A Sewer Use Ordinance (SUO) 5/20/13 ® Yes ❑ No 5/28/13 ® Yes ❑ No Enforcement Response Plan (ERP) 11/5/19 ® Yes ❑ No 2/5/20 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 4/17/20 ® Yes ❑ No 6/26/20 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 29. User Name 1. Spartan Dyers 2. US Cotton 3. 30. IUP Number 0009 0016 31. Does File Contain Current Permit? ® Yes ❑ I ® Yes ❑ I ❑ Yes ❑ No 32. Permit Expiration Date 11/5/24 3/11/26 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 410.70 410.70 IF- 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? I ® Yes ❑ No ® Yes ❑ No 11 ❑ Yes ❑ 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❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes ❑No a. ®Yes []No a. ❑Yes ❑No b. All Issues Resolved? b.❑Yes❑NoEN/A b.❑Yes❑NoEN/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No El ® N/A 11 ElYes ❑ No its Sampling as Required b IUP, includingflow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No 1 ❑ Yes ® N/A ❑ Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ❑Yes❑NoEN/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 ❑Yes❑NoEN/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoEN/A ❑Yes❑NoEN/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❑NoEN/AFE7cs❑No ❑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 EYes❑No❑NA ❑Yes❑NoEN/A ❑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❑NoEN/A ❑Yes❑NoEN/A ❑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❑NoEN/A a.❑Yes❑NoEN/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. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑NoEN/A c.❑Yes❑NoEN/A c.❑Yes❑No❑N/A violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No 11 ❑ Yes ® No 11 ❑ Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken EYes❑No❑N/A ❑Yes❑NoEN/A ❑Yes❑No❑N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑No❑N/A 49. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑NoEN/A a.❑Yes❑NoEN/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑NoEN/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ® No ❑ Yes ❑ No Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: 7. The City has issued US Cotton an Industrial User Permit (IUP); however, the SIU has not initiated a discharge to date. 17. Effluent fecal coliform limit violations were reported from January through July 2023. In addition, effluent TSS limit violations were reported from March 2023 through July 2023. These violations were attributed to an elevated solids inventory being maintained in the WWTP due to challenges associated with the removal of solids (land application, etc.). The City contracted a company in June 2023 with a portable belt press to lower the solids inventory via dewatering and landfill disposal. The WWTP returned to compliance in August 2023. 22. The City will revise the Long -Term Monitoring Plan (LTMP) to remove both the twice per year monitoring for uncontrollables and SIU listings. 25. The City staff will need to revise and resubmit the April 2023 and any additional eDMRs to correct the units of measurement of all applicable metals sampled during the LTMP sampling events. In addition, the quarterly effluent cyanide results (units of measurement) will need to be revised (if applicable) starting with the January 2022 eDMR. 35. The City performed the SIU inspections on 12/8/23 (Spartan Dyers) and 8/17/23 (US Cotton). 39. The City performs monthly sampling in lieu of the SIU. The POTW contracts Pace Analytical Services to perform all LTMP and IUP sampling and analyses. 46. The City issued Spartan Dyers a Notice of Violation (NOV) for an oil & grease limit violation in July 2023. Note: The NOV was not issued within the timeframe listed in the Division -approved Enforcement Response Plan (ERP) due to staff changes. SUMMARY AND COMMENTS: The City will update their LTMP to remove both the twice per year uncontrollable sampling and listing of SIUs. The City's Pretreatment staff must ensure all enforcement actions (NOVs, etc.) are issued within the timeframes listed in the Division -approved ERP. The City staffmust also review and revise/resubmit all applicable eDMRs to ensure all LTMP and quarterly (cyanide) results have been properly reported starting with the January 2022 eDMR. The pretreatment records were organized and well maintained. Overall, the City's Industrial Pretreatment Program was being properly implemented. NOD: [—]YES ® NO NOV: [—]YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ DocuSigned by: Fwela" 3/4/2024 PCI COMPLETED BY: DATE: Wes Bell, Environmental Specialist II, DWR/WQROS, Mooresville Regional Office DocuSigned by: PCI REVIEWED BY: DATE: 3/4/2024 C27DF9ACF858043F Brandy Costner, Assistant Regional Supervisor, DWR/WQROS, Mooresville Regional Office NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3