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Home My WebLink AboutNC0020621_Compliance Evaluation Inspection_20180423 ,;* ROY COOPER Governor MICHAEL S.REGAN Secretary Water Resources LINDA CULPEPPER Environmental Quality Interim Director April 23, 2018 Ms. Karen Reece, Pretreatment Coordinator Town of Boone P.O. Drawer 192 Boone, NC 28607 Subject: Pretreatment Compliance Inspection Report RECEIVED/DENR/DWR NPDES Permit# NC0020621 Jimmy Smith WWTP, Watauga County MAY 1 0 2018 Water Resources Dear Ms. Reece: Permitting Section On April 9, 2018, Paul DiMatteo of the Division of Water Resources Winston-Salem Regional Office conducted a Pretreatment Compliance Inspection at the above referenced wastewater treatment system. 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 judgement program, and adherence to the enforcement response plan (ERP). Background The Town operates a 4.82 MGD facility, and has two significant industrial users (SIU), one of which is categorical: Hospitality Mints and Charleston Forge. POTW Interview In 2017,the Town issued several Notices of Violation to both of its industrial users. Hospitality Mints was issued notices for BOD and TSS limits violations, as well as several issues that were identified with the lab used to collect and analyze samples. Charleston Forge was issued notices for flow meter installation, flow limits violations and a late TTO report. Neither of the SIUs were in significant noncompliance for the 2017 annual period. Pretreatment Program Elements Review The Headworks Analysis (HWA) renewal was submitted on July 31, 2015 and was approved on October 20, 2015.The next HWA was subsequently revised on August 29, 2017 and approved on October 26, 2017. The next HWA is due on October 1, 2020. The last Industrial Waste Survey (IWS) was submitted on March 17, 2014 and was approved on May 1, 2014.The next IWS is due April 1, 2019. -i2' Jr thing Compares:---, State of North Carolina I Environmental Quality 450 W Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105 Phone.336-776-9800\FAX 336-776-9797 f The last Long Term Monitoring Plan (LTMP) was submitted on August 29, 2017 and approved on September 19, 2017. The Sewer Use Ordinance (SUO) was approved on November 7, 2012. The ERP was approved on May 13, 2013. LTMP Review The LTMP is being conducted at the proper locations and frequencies. Industrial User Permit (IUP) File Review Hospitality Mint's permit (#0003) expires on June 30, 2018. A new application was submitted on February 12, 2018. Charleston Forge is a categorical user and its permit (#0004) expires on December 31, 2021. The monitoring and compliance/judgement were satisfactory. The chain of custody and lab reporting are in excellent order. During the 2017 calendar year,the Town issued and collected on one civil penalty against Hospitality Mints in the amount of$6,800 for violations that occurred during the 2016 calendar year. Action Items Ms. Reece said that she thought Bis(2-ethylhexyl) phthalate should be removed from the LTMP.This office recommends submitting a written request with justification to the NPDES PERCS unit for review. The pretreatment compliance inspection was satisfactory. The program is being implemented in an excellent manner. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-9691 or our office at (336) 776-9800. _ Sincerely, -1 kA. Y. Sherri V. Knight, P.E., Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures—PCI Report CC: PERCS Unit—Vivien Zhong WSRO Files Central Files f•- NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION[Complete Prior To PCI; Review Program Info Database Sheet(s)1 1 Control Authority(POTW)Name Boone—Jimmy Smith WWTP 2 Control Authority Representative(s) Karen Reece 3. Title(s) Lab Supervisor/Pretreatment Coordinator 4 Last Inspection Date• 3/30/2017 Inspection Type(Check One) ® PCI ❑ Audit 5 Has Program Completed All Requirements from the Previous Inspection and'Program Info Sheet(s)9 ®YES ❑ NO 6 Is POTW under an Order That Includes Pretreatment Conditions? ❑YES El NO Order Type,Number,Parameters. Are Milestone Dates Being Met? ❑YES ❑NO ICIS CODING Main Program Permit Number MM/DD/YY NIC 1 0 1 0 1 2 1 0 1 6 1 2 1 1 1 1 041 09 1 18 1 7 Current Number Of Significant Industrial Users(SIUs)9 2 8. Number of Sills With No IUP,or With an Expired IUP? 0 9 Number of SIUs Not Inspected By POTW m the Last Calendar Year? 0 10 Number of SIUs Not Sampled By POTW m 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 m SNC with Pretreatment Schedule? 0 14 Number of SIUs on Schedules? 0 15 Current Number Of Categorical Industrial Users(CIUs)7 1 16 Number of CIUs m SNC? 1 0 POTW INTERVIEW 17 Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑YES ®NO 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 ❑YES ®NO Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased Sludge Production,Etc)7 If Yes,How are these Problems Being Addressed' 19 Which Industries have been m SNC for Limits or Reporting during SNC for Limits None either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting None Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published None 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? None 21 Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ®NO Ones? LTMP/STMP FILE REVIEW: 22 Is LTMP/STMP Monitormg Being Conducted at Appropriate Locations and Frequencies? ® YES ❑NO 23 Are Correct Detection Levels bemg used for all LTMP/STMP Monitoring? ®YES ❑NO 24 Is LTMP/STMP Data Mamtamed m a Table or Equivalent? ®YES ❑NO Is Table Adequate? ®YES ❑ NO 25 All LTMP/STMP effluent data reported on Discharge Momtoring Report? ®YES❑NO Division Inspector,please verify yourself 26 IfNO to 23-26,list violations (Reviewed 1/2018 DMR) 27 Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP7 ❑YES ❑NO If yes,which ones?Elimmated: See Note 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 their files, complete with supporting 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) 7/31/2015 ®Yes ❑ No 10/20/2015 ® Yes ❑ No 10/1/2020 Industrial Waste Survey(IWS) 3/17/2014 ® Yes ❑ No 5/1/2014 ® Yes ❑ No 4/1/2019 Sewer Use Ordinance(SUO) 11/6/2012 ® Yes ❑ No 11/7/2012 ®Yes ❑ No Enforcement Response Plan(ERP) 2/22/2013 ® Yes ❑ No 5/13/2013 ® Yes ❑ No Long Term Monitoring Plan(LTMP) 8/29/2017 Z Yes ❑ No 9/19/2017 ® Yes ❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29 User Name 1 Hospitality Mints 2 Charleston Forge 3 30 IUP Number 0003 0004 31 Does File Contain Current Permit' ® Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No 32 Permit Expiration Date _ 06/30/2018 12/31/2021 33 Categorical Standard Applied(I E 40 CFR, Etc)Or N/A N/A 433 34 Does File Contain Permit Application Completed Within One Year Pnor ®Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 35 Does File Contam an Inspection Completed Within Last Calendar Year9 ®Yes ❑ No ® Yes ❑ No ❑Yes ❑ No 36 a Does the File Contain a Slug/Spill Control Plan9 a ZYes EINo a ZYes ❑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❑NoZN/A ®Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan(TOMP)? 38 a Does File Contain Original Permit Review Letter from the Division9 a ®Yes ❑No a ®Yes ❑No a. ❑Yes ❑No b All Issues Resolved9 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 flow9 40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ® Yes ❑ No ® Yes ❑ No ❑Yes ❑ No 41 During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/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❑NoNN/A ❑Yes❑No❑N/A file include process/dilution flows as Required by IUPC 42b For categoncal 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 by 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 SIU Sampling'? 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 Reporting Non-Compliance from SIU Sampling'? 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 Within 30 Days'? 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 becoming aware c❑Yes❑No®N/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 SIU in SNC' ❑ Yes ® No ❑ Yes ® No ❑ Yes ❑ No 47 During the Most Recent Semi-Annual Period, Was Enforcement Taken ®Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP(NOVs, Penalties,ti_-nmg, etc)9 - 48 Does the File Contain Penalty Assessment Notices'? ®Yes❑No❑N/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®N/A b❑Yes❑No❑N/A 51 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: 27.Karen said she thought Bis(2-ethylhexyl)phthalate should be removed from the LTMP because a priority pollutant scan showed only one spike in 2011 and she thought it came from the sampling jug. 49.Karen said that civil penalties are added to industry's utility bill.They don't generally keep proof of collection at the WWTP but it is obtainable. POTW had several violations from both IUs. All violations were identified and addressed.No SNC resulted. One civil penalty was assessed and collected 2017,for a violation in 2016. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY 1 1 1 1 1 1 1 1 I l l I 1 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 Equivalent? ❑YES ❑ NO 6 Did the POTW Contact Conduct the Followmg Parts of the Industrial Inspection Thoroughly'? Comments A Initial Interview ❑YES ❑NO B. Plant Tour ❑YES ❑NO C Pretreatment Tour ❑YES ❑ NO D Samplmg Review ❑YES ❑ NO E Exit Interview ❑YES ❑NO Industrial Inspection Comments Not conducted during PCI. OVERALL SUMMARY AND COMMENTS: Comments Boone's Pretreatment Program appears to be exceptionally well run Requirements Recommendations NOD: ❑YES ® NO NOV: ❑YES NO QNCR: ❑YES ®NO POTW Rating: Satisfactory / Marginal UnSatisfactory PCI COMPLETED BY: To---e DATE: q1117-41 NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3