NC0021547_Pretreatment Compliance Inspection_20170620

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Water- Resources
ENVIRONMENTAL QUALITY
June 20, 2017
Summer Woodard
Town Manager
Town of Franklin
PO BOX 1479
Franklin, NC 28744-1479
SUBJECT: Pretreatment Compliance Inspection
Town of Franklin WWTP
Permit No: NCO021547
Macon County
Dear Mr. Woodard:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZII"ERMAN
Director
RECEIVED/NCDEO/DWR
JUN 2 3 2017
vvalel 4.4ii 9liiy
Permitting Section
Enclosed please find a copy of the Pretreatment Compliance Inspection conducted on June 7, 2017. The
pretreatment program was found to be in compliance with permit NCO021547 and applicable pretreatment
regulations..
The attached North Carolina Division of Water Resources Pretreatment Compliance Inspection (PCI)
Report lists any additional items of importance noted during the inspection:
The assistance provided by Bill Deal during the inspection was greatly appreciated. Please refer to the
enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call me at 828-296-4500 or Monti Hassan at [phone] [e-mail].
Sincerely,
M. al�Vf liner
Environmental Specialist
Asheville Regional Office
Enc.
cc: Bill Deal, Pretreatment Coordinator/ORC
MSC 1617 -Central Files -Basement
Asheville Files
Monti Hassan, PERCS Unit
G:\WR\WQ\Macon\Wastewater\Municipal\Franklin WWTP 21547\Pre-Tx\PCI June 7, 2017\PCI letter 6-7-2017.doc
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

X
t: NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENYIRONMENTA00.411TY
BACKGROUND INFORMATION fComplete Prior To PCI• Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Franklin
2. Control Authority Representative(s): Bill Deal
3. Title(s): Pretreatment Coordinator/ORC
4. Last Inspection Date: 03/26/2015 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
NIQ10 10 1 2 1 11 514 1 71
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY .
106 107 117 1
7. Current Number Of Significant Industrial Users (SIUs)?
1
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 SILTS Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SILTS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
l_ 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 for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Put
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 Division Inspector, please verify yourself?
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element in 1$1
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 A
05/26/16
® Yes ❑ No
06/28/16
® Yes ❑ No
04/01/21
Industrial Waste Survey IWS)
05/14/14
® Yes ❑ No
08/04/14
® Yes ❑ No
04/01/19
Sewer Use Ordinance SUO
12/27/12
® Yes ❑ No
01/02/13
® Yes ❑ No
® Yes E] No ❑Yes ❑ No
Enforcement Response Plan RP
01/03/06
® Yes ❑ No
01/04/06
® Yes ❑ No
b. If No, is One Needed? (See Inspection Form from POTW)
Long Term Monitoring Plan (LTMP)
08/03/16
® Yes ❑ No
10/20/16
® Yes ❑ No
❑Yes❑No❑N/A
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Macon County 2. 3.
30. IUP Number
002
31. Does File Contain Current Permit?
® Yes [-]No ❑ Yes ❑ No
❑Yes El No
32. Permit Expiration Date
07/31/2021
33. Categorical Standard Applied .E. 40 CFR, Etc. Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No [07V;—sE1 No
❑ Yes [:1 No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes E] No ❑Yes ❑ No
❑ Yes ❑ No
36. a. Does the File Contain aSlug/Spill Control Plan?
a. []Yes ®No
a. ❑Yes END
a. ❑Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ®No I
b. ❑Yes []No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NOON/A❑Yes❑No❑N/A
11
❑Yes❑No❑N/A
Organic Management Plan TOMP)?
38. a. Does File Contain Original Permit Review Letter from the 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
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody F rms?
F ® Yes ❑ Lojj
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SlU Complete its
OYes❑No❑N/A
❑Y ![IN/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❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required b
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No❑N/A❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SILT Sampling?
®N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Reortin -Compliance from SIU Sam lin ?
44. a. Was the 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 W 30 Days9
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of b coming aware
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the S ?
46. During the Most Recent Semi -Annual Period, Was the SI J in SNC?
❑ Yes ® No
11 ❑ Yes ❑ No
11 ❑ Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enfor ement Taken
❑Yes❑No®N/AF
11
❑Yes❑No❑N/A
❑Yes❑No❑N/A
1
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
50. a. Does the 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❑No®N/A
b.❑Yes❑No[3N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obta' g Any of This
❑Yes ®No
❑Yes El No
El Yes E] No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Fo*m Updated December 2016 Page 2

FILE REVIEW COMMENTS:
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
IN IC 1 01 0 1 2 1 1 1 51 4 1 7I 1 061 07 117 1
1. Industry Inspected: Macon County
2. Industry Address: 1448 Lakeside Dr.
3. Type of Industry/Product: Landfill Leachate
4. Industry Contact: Chris Stahl Title: Solid Waste Director
Phone: [phone] Fax: [phone]
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:
Previously visited the landfill operations with Director Chris Stahl. Reviewed previous Landfill inspection with
Pretreatment Coordinator (Inspection was conducted 9-13-16). Landfill is run by the County and sits adjacent to the
WWTP. Leachate pond is located on-site of the WWTP. Previous Industrial Inspections indicate the WWTP did not
require a Spill/Slug Response Plan from Macon County. Bill Deal, stated any spill of leachate would drain to the
leachate pond on-site. ORC also has ability to shut off flow in the event of an upset.
OVERALL SUMMARY AND COMMENTS:
Comments: Pretreatment program appears to be well maintained. Documents and monitoring data are kept in binders by monitoring year.
Requirements:
Recommendations: May wish to compile data in an excel spreadsheet for ease of tracking and monitoring.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal
UnSatisfactory
PCI COMPLETED BY: Mikal Willmer DATE: 06/07/2017
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3