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Home My WebLink AboutNC0021733_Inspection_20181008NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Marshall WWTP 2. Control Authority Representative(s): Donald Byers 3. Title(s): Pretreatment Coordinator/ORC 4. Last Inspection Date: 9/15/16 Inspection Type (Check One): Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? There were no requirements from the previous inspection. 6. Is POTW under an Order That Includes Pretreatment Conditions? NO Order Type, Number, Parameters: _______________________________ Are Milestone Dates Being Met? YES NO ICIS CODING Main Program Permit Number MM/DD/YY | N | C | 0 | 0 | 2 | 1 | 7 | 3 | 3 | | 9 | 20 | 18 | 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? 1 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? 1 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? na 14. Number of SIUs on Schedules? 0 15. Current Number Of Categorical Industrial Users (CIUs)? 1 16. Number of CIUs in SNC? 1 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? YES NO 1 TSS and 1 BOD violation in Oct 2016 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? YES NO 19. Which Industries have been in SNC for Limits or Reporting during either of the Last 2 Semi-Annual Periods? Not Been Published for Public Notice?(May refer to PAR if Excessive SIUs in SNC) SNC for Limits:1 SNC for Reporting:0 Not Published:1 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 Ones? 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. 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:_______________________ DocuSign Envelope ID: F0C3D842-6937-4697-A5AD-DB3404E8A0F9 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 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) 08/19/2014 Yes No 5/7/2015 Yes No 3/1/2020 Industrial Waste Survey (IWS) 2/8/2014 Yes No 2/18/2014 Yes No 12/31/2018 Sewer Use Ordinance (SUO) 1/3/2012 Yes No 3/21/2013 Yes No Enforcement Response Plan (ERP) 10/27/2008 Yes No 11/20/2008 Yes No Long Term Monitoring Plan (LTMP) 5/22/2011 Yes No 8/10/2011 Yes No ________________________________________________________________________________________________________________ INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Derringer-Ney Inc 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? Yes No Yes No Yes No 32. Permit Expiration Date 4/15/2020 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 468.14, 471.44 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No 36. a. Does the File Contain a Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) a. Yes No b. Yes No a. Yes No b. Yes No a. Yes No b. Yes No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? Yes No N/A Yes No N/A Yes No N/A 38. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. Yes No b.Yes No N/A a. Yes No b.Yes No N/A a. Yes No b.Yes No N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP, including flow? Yes No Yes No Yes No 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 Sampling as Required by IUP, including flow? Yes No N/A Yes No N/A Yes No N/A 41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports on time? Yes No N/A Yes No N/A Yes No N/A 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? Yes No N/A Yes No N/A Yes No N/A 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? Yes No N/A Yes No N/A Yes No N/A 43a. During the Most Recent Semi-Annual Period, Did the POTW Identify All Limits Non-Compliance from Both POTW and SIU Sampling? Yes No Yes No Yes No 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/A Yes No N/A Yes No N/A 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? 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 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 as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? Yes No N/A Yes No N/A Yes No N/A 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 Collect ion? Yes No N/A Yes No N/A Yes No N/A 50. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 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 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? Yes No Yes No Yes No DocuSign Envelope ID: F0C3D842-6937-4697-A5AD-DB3404E8A0F9 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 FILE REVIEW COMMENTS: 35. Mr. Byers said that they do a general inspection at Derringer when they take quarterly samples although the inspection aspect has not been documented. 43a. POTW failed to identify SNC for cadmium and oil/grease limits. 44a. Unknown if Derringer realized that they violated the limits of their permit. 46.Yes, but this was not recognized by the POTW. 47. No, the SNC was not recognized by the POTW. 51. Yes, they could not show me a documented inspection in the past year. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY | N | C | 0 | 0 | 2 | 1 | 7 | 3 | 3 | | 9 | 20 | 18 | 1. Industry Inspected: Derringer-Ney Inc 2. Industry Address: 10 Derringer Dr., Marshall, NC 28753 3. Type of Industry/Product: Metal Plating/Extrusion 4. Industry Contact: Ray Flynn Title: Maintenance Supervisor Phone: 828-649-3842 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: The POTW seems to have failed to recognize that Derringer-Ney was in SNC even though it had regular permit violations. __________________________________________________________________________________________________________ Requirements: Marshall WWTP needs to send an NOV to Derringer for SNC and issue a Public Notice of the SNC at the beginning of 2019. __________________________________________________________________________________________________________ Recommendations: ____________________________________________________________________________________________ __________________________________________________________________________________________________________ NOD: YES NO NOV: YES NO QNCR: YES NO POTW Rating: Satisfactory Marginal UnSatisfactory X PCI COMPLETED BY: Daniel Boss DATE: ________10/05/2018___________________________ DocuSign Envelope ID: F0C3D842-6937-4697-A5AD-DB3404E8A0F9