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HomeMy WebLinkAboutNC0032077_NOD-2018-PC-0167_20180510 = *01470, J May 10, 2018 Charles M. Smithwick, Jr Contentnea Metropolitan Sewerage District PO Box 477 Grifton, NC 28530-0477 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2018-PC-0167 Permit No. NC0032077 Contentnea Sewerage District WWTP Pitt County Dear Mr. Smithwick: The North Carolina Division of Water Resources conducted an Pretreatment Compliance Inspection of the Contentnea Sewerage District on May 9, 2018. A summary of the findings and comments noted during the inspection is provided in the enclosed copy of the Pretreatment Compliance inspection report. The following Deficiencies were noted during the inspection. Inspection Area Description of Deficiency Pretreatment Carolina Classics Catfish limit violations in July 2017 for Oil and Grease and December 2017 limit violation for flow. CMSD needs to follow ERP for IUP permit violations Pretreatment Weyerhaeuser limit violation in February 2017 for BOD. CMSD needs to follow ERP for IUP permit violations 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. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. State of North Carolina I Environmental Quality I Water Resources 943 Washington Square Mall,Washington,NC 27889 252-946-6481 If you should have any questions, please do not hesitate to contact Robbie Bullock with the Water Quality Regional Operations Section in the Washington Regional Office at 252-946-6481. Sincerely, rpeld. tit/ Robert Tankard, Assistant Regional Supervisor Water Quality Regional Operations Section Washington Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: WQS Washington Regional Office — Pretreatment File Monti Hassan - PERCS State of North Carolina I Environmental Quality I Water Resources 943 Washington Square Mall,Washington,NC 27889 252-946-6481 NORTH CAROLINA DIVISION OF WATER QUALITY PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1 • 1. Control Authority(POTW)Name: Contentnea Metropolitan Sewerage District 2. Control Authority Representative(s): Renee Smith 3. Title(s): Pretreatment Coordinator 4. Last Inspection Date: 6/2/2016 Inspection Type(Check One): ❑ PCI ® Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ YES ❑NO N/A 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑YES ® NO Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑YES ❑NO PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type l NJ J NICO J O 13 12 10 1 7 17 J 1 5 19 1 18 1 J P J J S [ 11 (DTIA) (TYPI) (INSP) (FACC) 7. Current Number Of Significant Industrial Users(SIUs)? 3 SNS 8. Current Number Of Categorical Industrial Users(CIUs)? 1 CNS 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.Enter the Higher Number of 9 or 10 0 NON 12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM 13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 0 Semi-Annual Periods(Total Number of SIUs in SNC) PSNC 14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC 15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 0 SNPS 16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0 Semi-annual Periods 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.)? If Yes,How are these Problems Being Addressed? 19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:0 either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:0 Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: 0 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? 0 21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ®NO Ones? 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 10/2017 DMR verified 26. IfNO 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 DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1 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 Last Approval Date Next Due, Date In file? Date - In file If Applicable Headworks Analysis(HWA) 10/1/2015 ®Yes❑ No 1/26/2016 ®Yes❑ No 9/30/2020 Industrial Waste Survey(IWS) 11/12/2015 ®Yes❑ No 12/21/2015 ® Yes❑ No 10/1/2020 Sewer Use Ordinance(SUO) 12/17/2012 ®Yes❑ No 1/4/2013 ®Yes❑ No Enforcement Response Plan(ERP) 6/29/2010 ®Yes❑ No 9/20/2010 ®Yes❑ No Long Term Monitoring Plan(LTMP) 1/15/2015 ®Yes❑ No 2/5/2015 ®Yes❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1.Winterville Machine Works 2.Carolina Classics 3.Weyerhaeuser Catfish 30. IUP Number 1111 1114 1115 31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No 32. Permit Expiration Date 9/30/2021 9/30/2021 9/30/2021 33. Categorical Standard Applied(I.E.40 CFR,Etc)Or N/A 413,Subpart A N/A N/A 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 Las:Calendar Year? ® Yes ❑ No ®Yes ❑ No ®Yes ❑ No 36. a.Does the File Contain a Slug/Spill Control Plan? a. ZYes❑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❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No®N/A Organic Management Plan(TOMP)7 38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes❑No a. ®Yes ❑No a. ®Yes ENo 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 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❑No®N/A ❑Yes❑NoNN/A file include process/dilution flows as Required by IUP? 42b.For categorical IUs with Production based limits,does fle include ❑Yes❑NoNN/A ❑Yes❑NoNN/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? N/A N/A 43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoZN/A ❑Yes❑NoZN/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❑NoNN/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❑NoNN/A as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No NN/A ❑Yes❑NoZN/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoE1N/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❑NoNN/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes ® No Requested Information For You? NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2 FILE REVIEW COMMENTS: Carolina Classics Catfish had 2 permit violations during 2017.In July 2017 the facility violated the Oil and Grease permitted limit.The sample result was 589 mg/1 with the permitted limit of 500 mg/1. On December 6,2017 Carolina Classics Catfish violated their permit limit for flow. The permitted flow limit is 36,000 gpd and the actual flow was 36,100 gpd. Weyerhaeuser had 1 permit violation during 2017. In February 2017 the facility violated their permitted limit for BOD.The sample result was 567 mg/1 with the permitted limit of 500 mg/l. The facility was reminded that Notice of Violations or Notice of Non-Compliance must be sent to SIU's for permit violations according to CMSD's Enforcement Response Plan. INDUSTRY INSPECTION PCS CODING: Trans.Code • Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type I__ 1 1 1 1 1 1 1 1 I l l I 1 l l I l 1 S l 1 2 1 (DTIA) (TYPI) (INSP) (FACC) 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 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: OVERALL SUMMARY AND COMMENTS: Comments: Files were readily available and neatly organized. Requirements: CMSD's Enforcement Response Plan must be followed when SIU's violate their permitted limits. Recommendations: NOD: e YES ❑ NO NOV: ❑YES ❑NO QNCR: ❑YES ❑ NO POTW Rating: Satisfactory / Marginal i UnSatisfactory PCI COMPLETED BY: ,✓ 1�-, ' DATE: ? /l NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3