The URL can be used to link to this page

Home My WebLink AboutNC0020940_NOV2024PC0521_PCI_20240916Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F ROY COOPER Governor ELIZABETH S. BISER sccmCry RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality SENT VIA ELECTRONIC MAIL ONL Y. NO HARD COPY WILL BE MAILED. September 16, 2024 Chad B Simons, Manager Town Town of Murphy Email: manager@townofmurphync.com SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2024-PC-0521 Permit No. NCO020940 Murphy WWTP Cherokee County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Murphy WWTP on August 26, 2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0020940. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Pretreatment Compliance inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Pretreatment A new HWA is past due and needs to be submitted. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. D_EQ� firth[arollna9egartmenlofFm9ronmrntalQualhVlDivlsWnaFWaterResaurcrs Ashcvllk Rc9knalMcc12050U.5.HVgh-y70 I8—n—.N.rthc 11n.28776 wu.wnwr.wv..nwoin� 62&2%4500 Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Rachel Rose with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. ATTACHMENTS: Inspection Report Ec: Laserfiche Tyler White (ORC) Sincerely, EP DocuSigned by: a,V ACt 66SS E397192DABFB4FF... Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ Carolllgnpl rrmenlof0U S. Mgh-1 Qua1 DivlskmN.rth Cr Resources Ashc+llk Rc9knal Officc 205p U.S. Hlghv+ay 70 Swannanoa, North Camllna 28776 62&2%4500 Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F 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 2 u 3 I NCO020940 111 121 24/08/26 I17 18 L D I 19 I s I 201 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 73 � I 74 79 I I I I I I I80 70 I 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) 10:OOAM 24/08/26 20/03/01 Murphy WWTP Payne St Exit Time/Date Permit Expiration Date Murphy NC 28906 12:OOPM 24/08/26 24/08/31 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 Tyler White,PO Box 130 Murphy NC 289060130//828-837-5035/ 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 Rachel Rose pocusigned by: DWR/ARO WQ/828-296-4500/ 9/16/2024 E, 94 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date by: 9/16/2024 FpD—S,g"ed EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F NPDES yr/mo/day Inspection Type (Cont.) NCO020940 I11 12I 24/08/26 117 18 1 p I Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Rachel Rose, with the Asheville Regional Office, conducted a Pretreatment Compliance Inspection (PCI) of the Town of Murphy's Pretreatment Program on August 26, 2024. Tyler White (ORC & Pretreatment Coordinator) was present during the inspection. Overall, the program is marginally in compliance with the Federal and State Pretreatment Program requirements. The Town of Murphy (NPDES Permit No. NC0020940) has three Significant Industrial Users all of which are Categorial Industrial Users. The following was noted during the file review: The Town of Murphy experienced a data loss leading to the SUO approval letter and the ERP approval letter being lost. A new HWA is past due and needs to be submitted. MOOG (IUP 0001) is a zero discharge industry; the industrial water used is either recycled or sent off to landfills. The groundwater remediation permit on -site is separate from MOOG. The following violation was noted during the inspection: 1. A new HWA is past due and needs to be submitted. Page# Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F .a NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL OVAL I TY BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l 1. Control Authority (POTW) Name: Town of Murphy 2. Control Authority Representative(s): Tyler White 3. Title(s): ORC & Pretreatment Coordinator 4. Last Inspection Date: 09/23/2021 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 Order Type, Number, Parameters: ICIS CODING Main Program Permit Number NIC10 10 1 21 01 91 41a1 MM/DD/YY 1 08 1 26 1 24 J Are Milestone Dates Being Met? ❑ YES ❑ NO 7. Current Number Of Significant Industrial Users (SIUs)? 3 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 ? 3 16. Number of CIUs in SNC? 11 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? The Town of Murphy WWTP had Fecal Coliform exceedances in December 2023, February 2024, and April 2024. The broken chlorine pump head was replaced April 2024. 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 FENot either of the Last 2 Semi -Annual Periods? Not Been Published for Public Notice?(May refer to PAR if Excessive SIUs in SNC) 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: 0 Reporting: 0 ,lished: 0 0 ❑ 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 Inspector, please verify yourself! 26. 27. If NO to 23 - 26, list violations 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 Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F If yes, which ones? Eliminated: Added: 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) ® Yes ❑ No 02/12/2019 ® Yes ❑ No 09/30/2023 Industrial Waste Survey IWS 01/14/2019 ® Yes ❑ No 01/22/2019 ® Yes ❑ No N/A Sewer Use Ordinance SUO 03/4/2013 ® Yes ❑ No 03/25/2013 ❑ Yes ® No Enforcement Response Plan ERP 06/25/2009 ® Yes ❑ No 08/31/2009 ❑ Yes ® No Long Term Monitoring Plan (LTMP) 1 07/11/2022 ® Yes ❑ No 07/12/2022 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Snap-On 2. 3. 30. IUP Number 31. Does File Contain Current Permit? 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 to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? 36. a. Does the File Contain a Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? 41. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self - Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? c. If applicable, Did POTW resample within 30 days of becoming aware 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? 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? 49. Does The File Contain Proof Of Penalty Collection? 50. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? 0005 ® Yes ❑ I ❑ Yes ❑ 1 ❑ Yes ❑ No 03/05/2027 433.17 ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No a. ®Yes ❑No b. ❑Yes [:]No a. ❑Yes ❑No b. []Yes []No a. ❑Yes ❑No b. ❑Yes ❑No ®Yes❑No❑N/A 7e�00N/A ❑Yes❑No❑N/A a. ®Yes ❑No b.❑Yes❑No®N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A ® Yes ❑ !11 ❑ Yes ❑ No ❑ Yes ❑ No ® Yes ❑ I ❑ Yes ❑ NoI ❑ Yes ❑ No ®Yes❑No❑N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A ®Yes❑No❑N/A 77`oo ❑Yes❑No❑N/A ❑Yes❑No®N/A 7es E]N/A 11 ❑Yes❑No❑N/A ❑Yes❑No[g ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No®N/A ❑ Yes ❑ No ❑ Yes ❑ No ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c.❑Yes❑No❑N/A ❑ Yes ® No 11 ❑ Yes ❑ No I ❑ Yes ❑ No ❑Yes❑No®N/A ❑Yes❑No❑N/A pYes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A ❑ Yes ®No1F ❑Yes ❑ !oF Yes ❑ No NC DA R Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 Docusign Envelope ID: 875B8A65-A28F-4EA1-B442-18D6E70CF73F FILE REVIEW COMMENTS: The Town of Murphy experienced a data loss leading to the SUO approval letter and the ERP approval letter being lost. A new HWA is past due and needs to be submitted. MOOG (IUP 0001) is a zero discharge industry; the industrial water used is either recycled or sent off to landfills. The groundwater remediation permit on -site is separate from MOOG. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY I N I C 1 0 1 0 1 2 1 0 1 9 1 4 1 0 1 1 08 1 26 1 24 1 1. Industry Inspected: MOOG (IUP 0001) 2. Industry Address: 1995 NC-141 Murphy, NC 28906 3. Type of Industry/Product: Motor Coating for Medical & Military Motors 4. Industry Contact: Danielle Lloyd Title: Facilities & EH Manager Phone: 828-361-9706 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: Part of the facility was under construction at the time of the inspection, so a full plant tour was not possible but an adequate amount of the facility was inspected. OVERALL SUMMARY AND COMMENTS: Comments: Requirements: Recommendations: NOD: ❑ YES ❑ NO NOV: ® YES ❑ NO QNCR: ❑ YES ❑ NO POTW Rating: Satisfactory Marginal X UnSatisfactory PCI COMPLETED BY: Rachel Rose DATE: 9/16/2024 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3