NC0020036_Pretreatment Audit Inspection_20150708

A7A
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
July 8,2015
Mr. Heath Jenkins RECEIVED/DENRIDWR
Interim Town Manager
Town of Stanley ,JUL 1 4 2 015
114 South Main Street
Stanley,North Carolina 28164 Water Quality
Permitting Section
Subject: Pretreatment Audit Inspection
Town of Stanley
NPDES Permit No.NC0020036
Gaston County
Dear Mr. Jenkins:
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the Town of Stanley
approved Industrial Pretreatment Program on July 1, 2015 by Mr. Wes Bell of this Office.
The report should be self-explanatory;however, should you have any questions concerning this report,please
do not hesitate to contact Mr. Bell at(704)235-2192, or at [e-mail].
Sincerely,
114- /.9/
Michael L. Parker,Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources,DENR
Enclosure:
Inspection Report
cc: Sarah Bass,PERCS Unit
MSC 1617-Central Files/Basement
WB
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone] Customer Service:1-877-623-6748
Internet:www.ncwaterquality.org
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NtDENR NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority(POTW)Name: Town of Stanley
2. Control Authority Representative(s): Craig Roseberry,Janet Maddox,David Shellenbarger,Charlie Graham
3. Title(s):Public Works Director;Two Rivers Utilities-Pretreatment Coordinator,Asst.Division Managers
4. Address of POTW:
Mailing 114 S.Main Street
City Stanley Zip Code 28164
Phone Number [phone] Fax Number [phone] E-Mail croseberrytownofstanlev.org
5. Audit Date 07/01/2015
6. Last Inspection Date: 06/13/2013 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. Monthly average effluent ammonia violation in March 2014; monthly average effluent BOD
violation in December 2014;weekly average effluent BOD,TSS and fecal coliform violations and a daily maximum
effluent copper violation in December 2014;weekly average effluent fecal coliform violation in February 2015.
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
PCS(WENDB)Coding:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
INI INlclo l0 12 1010 13 16 1 1071011141 IGI Isl Lii
(DTIA) (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users(SIUS)? 1 SIUS
11. Current Number of Categorical Industrial Users(CIUS)? 0 CNS
12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0
14. Enter Higher Number of 12 or 13 0 NOIN
15. Number of SIUs with No IUP,or with an Expired IUP 0 NOCM
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 0 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi-Annual Periods 0 MSNC
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods 0 SNPS
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0
Semi-Annual Periods
20. Number of SIUs in SNC for Self-Monitoring Requirements that were Not Inspected or Sampled 0 SNIN
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21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable '
Headworks Analysis(HWA) 6/4/13 ®Yes 0 No 11/20/13 ®Yes 0 No 4/1/18
Industrial Waste Survey(IWS) 11/9/12 ®Yes❑ No 2/4/13 ®Yes El No 11/1/17
Sewer Use Ordinance(SUO) 8/28/13 ►ii Yes 0 No 9/10/13 ®Yes 0 No
Enforcement Response Plan(ERP) 12/8/94 ®Yes 0 No 1/11/95 ®Yes 0 No
Long Term Monitoring Plan(LTMP) 3/22/12 ®Yes❑ No 6/19/12 ®Yes El No
Legal Authority(Sewer Use Ordinance-SUO)
22. 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.
23. If yes to#22,Do you have current Interjurisdictional Agreements(IJAs)or other Contracts? ❑Yes❑ No ®NA
A copy,if not already submitted,should be sent to Division.
24. If yes to#22,Have you had any trouble working with these towns or districts? 0 Yes 0 No ®NA
If yes,Explain.
25. Date of Last SUO Adoption by Local Council 4/1/2013
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ®Yes El No
If no,POTW must send copy within 30 days.
28. 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.
29. List Industries under a Schedule or Order and Type of Schedule or Order
NA
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal 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 OM❑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
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31. Does the POTW have an adequate data management system to run the pretreatment program? ®Yes 0 No
Explain Yes or No.Computer spreadsheet.
32. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
The Town currently does not recover the Pretreatment Program costs; however,Town personnel are in the process of
determining a fee schedule for the SIU in the future to recover these costs.
Public Perception/Participation:
33. Are there any local issues affecting the pretreatment program (e.g..odor,plant closing,new or proposed plants)?
®Yes❑ No If yes,Explain.The Town is currently in the process of connecting the WWTP to the Two Rivers Utilities'
collection system. The construction activities are projected to be completed in October 2015.
34. 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?The request would be made in writing and would be
handled by the Town and the Two River Utilities/Pretreatment Coordinator.
35. 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?.The request would be made in writing to Town and Two Rivers
Utilities/Pretreatment Coordinator. Confidential files would be kept in a locked file cabinet.
36. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes❑ No
37. Is the public notified about changes in the SUO or Local Limits? ®Yes 0 No
38. Were all industries in SNC published in the last notice? 0 Yes❑ No ® NA
Permitting(Industrial Waste Survey-IWS):
39a...How does the POTW become aware of new or changed Users?Town Manager attends meetings with Economic
Development personnel and forwards the information to the Two Rivers Utilities/Pretreatment Coordinator.
39b.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?)Pretreatment Coordinator will evaluate short form and issue long form if applicable. The Pretreatment
Coordinator will evaluate the loading,industrial processes,flow volume,and any categorical processes.
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)The Town does not accept trucked waste and/or septage haulers.
43. How does the POTW allocate its loading to industries?Mark all that apply
0 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?NA
45. If yes to#43,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
NA
46. Does the POTW keep pollutant loading in reserve for future growth/safety? 0 Yes 0 No®NA
If yes,what percentage of each parameter %.The WWTP will be connected to the Two Rivers Utilities'collection
system by October 2015.
47. Has the POTW experienced any difficulty in allocation?(for example: adjudication by an industry) 0 Yes❑ No
If yes,Explain.NA
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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.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Monitoring requirements would be based on discharge frequency and loading.
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.NOVs for limit violations;Division's Compliance Judgement
Worksheet for SNC determinations;NOV for monitoring violations,escalating enforcement for continued violations
(monitoring and limit).
52. Does the POTW use the Division's model inspection form or equivalent? ®Yes❑ No
If no,does the POTW form include all DWQ data? El Yes❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ®Yes 0 No
If no,Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
A standardized checklist is used to evaluate the chemcial storage practices,presence and location of floor drains,potential
impacts to WWTP
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contacts are up to date,presence of emergency response equipment,appropriate containment structures,spill prevention
equipment,and adequate reporting plan.
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling point would be at the end of all treatment processes and separate from domestic waste stream.
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.POTW performs all sampling,Two Rivers Utilities
has a sampling SOP.
58. Who performs sample analysis for the POTW for:
Metals Two Rivers Utilities
Conventional Parameters Two Rivers Utilities
Organics Shealy Environmental Services.Inc.
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Internal chain of custody(COC)form for Two Rivers Utilities'Lab and the commercial lab's COC if needed.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA):Not Applicable
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? El YES ❑NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑YES El NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ❑YES El NO Is Table Adequate? 0 YES El NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)?El YES El NO DWQ Inspector,verify yourself!
60e. If NO to any above,list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? El YES ❑NO
If yes,which ones?Eliminated: Added:
61. Do you complete your own headworks analysis(HWA)? ❑Yes El No
If no,Who completes your HWA? Phone( )
62. Do you have plans to revise your HWA in the near future? El 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.
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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.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
None at this time; however,the Town's Pretreatment Program status will be re-evaluated within the near future due to the
pending connection of the WWTP to the Two Rivers Utilities'collection system.
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW:
66. User Name I 1.NA 2. 3.
67. IUP Number
68. Does File Contain Current Permit? 0 Yes /771 ❑Yes ❑ No ❑Yes ❑ No
69. Permit Expiration Date
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A
71. Does File Contain Permit Application Completed Within One Year Prior ■ Yes ■ No ■ Yes ■ No 0 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. OYes ONo a. OYes ONo a. OYes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b. OYes ONo b.OYes ONo b.OYes ONo
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic OYes ONo OYes ONo OYes ONo
Organic Management Plan(TOMP)? ON/A ❑N/A ON/A
75. a.Does File Contain Original Permit Review Letter from Division? a. OYes ONo a. OYes ONo a. OYes ONo
b.All Issues Resolved? b.❑Yes❑NoON/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ❑Yes 0 No ❑Yes ❑ No ❑Yes 0 No
Sampling as Required by IUP,including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? 0 Yes ❑ No • Yes ■ No ■ Yes ■ No
78. During Most Recent Semi-Annual Period,Did SIU Complete its OYes ONo OYes ONo OYes ONo
Sampling as Required by IUP,including Flow? ON/A ❑N/A ON/A
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ❑Yes ONo OYes ONo OYes ONo
time? ❑N/A ❑N/A ❑N/A
80a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes ONo OYes ONo ❑Yes ONo
file include process/dilution flows as Required by IUP? ON/A ON/A ON/A
80b.For categorical lUs with Production based limits,does file include OYes ONo OYes ONo ❑Yes ONo
production rates and/or flows as Required by IUP? ON/A ON/A ❑N/A
81. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes ❑ No ❑Yes ❑ No ■ Yes ■ No
Limits Non-Compliance from Both POTW and SIU Sampling? ❑NA ❑NA ❑NA
82. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Reporting Non-Compliance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes ONo ON/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
becoming aware of SIU limit violations in the POTW's sampling of SIU? c.❑YesONo❑N/A c.❑yes❑No❑N/A c.❑Yes❑No❑N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? ❑Yes 0 No ❑Yes ❑ No ❑Yes ❑ No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Specified in POTW's ERP(NOVs,Penalties,timing,etc.)?
86. Does File Contain Penalty Assessment Notices? ❑Yes❑No❑N/A ❑Yes❑No❑N/A r DYes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection? ❑Yes❑No❑N/A ❑Yes❑No❑N/A I ❑Yes❑No❑N/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑YesONo❑N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A
b.Is SIU in Compliance with Order? b.❑Yes❑No❑N/A b.❑Yes❑NooN/A b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested Yes No 0 Yes 0 No 0 Yes 0 No
Information For You?
FILE REVIEW COMMENTS:
2. The Town has contracted Two Rivers Utilities to implement the Town's Pretreatment Program.
22. The City of Mt.Holly receives wastewater from the Town under the Wastewater Interconnnect Agreement effective 3/4/96.
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68. The previous SIU (Outdoor Lifestyles) performed the last batch discharge event on 6/11/14 prior to shutting down operations.
Prism Laboratories, Inc. was contracted to perform the analyses. The Town performed the sampling for the S . The SIU
permit was dropped on 5/14/15. No discharges occurred during the second half of 2014.
J&L Machine& Fabrication IUP became effective on 4/13/15_and expires 12/31/18. The Town/Two Rivers Utilities staff performed
an inspection on 4/7/15 and will continue to perform all permit-required sampling. The SIU initiated the first discharge event
(batch) on 6/29/15. Two Rivers Utilities lab will perform all analyses except TTO parameters. Shealy Environmental Services,
Inc.will be contracted to perform the TTO analyses.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
N N C 0 0 2 0 0 3 6 7 1 15 U S 2
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: J&L Machine&Fabrication
2.Industry Address: 201 S Buckoak Street,Stanley,NC 28164
3.Type of Industry/Product: Machine Fabricated Parts
4.Industry Contact: Joel Hardin Title: Owner Phone: [phone] Fax: [phone]
5.Does the POTW Use the Division Model Inspection Form or Equivalent? ®Yes El No
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ®Yes 0 No
B. Plant Tour ®Yes ❑ No
C. Pretreatment Tour ®Yes ❑ No
D. Sampling Review ®Yes ❑ No
E. Exit Interview ®Yes ❑ No
Industrial Inspection Comments:
The fabricated machine parts are conveyed through a 4-stage rinse system prior to the powder coating system. The spent rinse
water is screened (in rinse tanks) and collected into a sedimentation pit for grit removaL The rinse water pH is also adjusted
(sodium hydroxide)on an as-needed basis. The small amount of solids that accumulates in the pit are removed and placed into
a dumpster. Spent coolants from the machining operations are collected in a tote bin and removed by a third party for
recycling.
SUMMARY AND COMMENTS:
Audit Comments: The POTW will submit an updated ERP.
The records were organized and well maintained. The POTW's Pretreatment Program is being properly implemented.
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Margi 1 0 Unsatisfactory❑
/Audit COMPLETED BY: i% f— -c" `-'lDATE: July 7,2015
Wes Bell,WQROS,Mooresville Regional Office
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