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Home My WebLink AboutNC0055786_Inspection_20181005 I 4r,i-i-t.---filK;c0-, ,k4j, .,---vide- ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary LINDA CULPEPPER Interim Director October 5, 2018 Mr. Tom Johnson- Water Resources Director RECEIVED/DENR/DVR City of Lexington 28 West Center Street OCT 17 2018 Lexington,NC 27292 Water Resources Permitting Section SUBJECT: Pretreatment Compliance Inspection (PCI) City of Lexington NPDES#NC0055786 Davidson County Dear Mr. Johnson: On September 18, 2018 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski of the Winston-Salem Regional Office. The purpose of this inspection was to determine the effectiveness of the City's pretreatment program,which includes reviewing the files, including industrial monitoring data,POTW plant performance, and adherence to the enforcement response plan(ERP). Backgrround The City has six (6) Significant Industrial Users (SIUs), five (5) of which are categorical. The treatment plant is permitted for 6.5 MGD. I POTW Interview The fecal coliform weekly average limit of was exceeded for the week of 2/5/2018. The BOD Monthly limit of was exceeded by 0.1 mg/L in June 2018. Pretreatment Program Elements Review The last Headworks Analysis (HWA)renewal was submitted on January 9, 2015. The HWA was approved on June 10, 2015. The next HWA is due on July 1, 2019. The last Industrial Waste Survey(IWS)was submitted on January 9,2015. The IWS was approved on February 6, 2015. The next IWS is due on October 1, 2019. The Sewer Use Ordinance (SUO) was approved on January 9, 2013. The Enforcement Response Plan(ERP)was approved on July 2, 2010. ,,111:01Q,) NORTH CARouNI oewRNN,t alEnvironmentala�ro� 4 North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103 336.776.9800 The Long Term Monitoring Plan(LTMP)was approved on November 4, 2016. LTMP File Review The LTMP is being conducted at the proper locations and frequencies. Industrial User Permit (IUP) File Review None of the six (6) SIUs were in significant noncompliance (SNC) in 2017. A review of the file for Leggett#2 (#0028) revealed that the monitoring data was well organized and compliant. A review of the file for Cardinal Containers (#0010) revealed that the monitoring data was well organized and compliant. A review of the file for Tier Rack (#0045) revealed that the monitoring data was well organized and compliant. The slug control plan for Leggett#2 (#0028)was in good order. The slug control plan for Cardinal Containers (#0010)was in good order. The slug control plan for Tier Rack(#0045)was in good order. Action Items No other action items were noted. The pretreatment program is considered satisfactory. Ms. Minerali continues to maintain an effective pretreatment program. If you have any questions please contact Jim Gonsiewski or me at (336) 776-9800. Sincerely, Sherri V. Knight, PE Regional Supervisor Water Quality Regional Operations Section Division of Water Resources,NCDEQ—WSRO Enclosure—PCI Report cc: PERCS Unit—Monti Hassan Eglantina Minerali—City of Lexington Central Files WSRO Files NORTH CAROLINA DIVISION OF WATER RESOURCES . PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT Water Resources EVVIRONMENI AL GOAL TY BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] 1. Control Authority(POTW)Name: Lexington Regional Wastewater Treatment Plant 2. Control Authority Representative(s): Eglantina Minerali 3 Title(s):Laboratory Supervisor/Pretreatment Program Coordinator 4. Last Inspection Date: 09/22/2017 Inspection Type(Check One): ❑ PCI ►1 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: Are Milestone Dates Being Met? ❑ YES ❑NO ICIS CODING Main Program Permit Number MM/DD/YY 1 NICI0 10 1515 17 18 16 J09 118 118 1 7. Current Number Of Significant Industrial Users(SIUs)? 6 8. Number of SllUs With No IUP, or With an Expired IUP? 0 9. Number of SllUs 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.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods? 0 12.Number of S:Us 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)? 5 16. Number of CIUs in SNC? 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? The fecal coliform weekly average limit was exceeded for the week of 2/5/18. The BOD monthly limit was exceeded by 0.1 mg/L in June 2018. 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: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: N/A 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 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 I 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) 01/09/2015 ® Yes ❑ No 06/10/2015 ®Yes ❑ No 07/01/2019 Industrial Waste Survey(IWS) 01/09/2015 ® Yes ❑ No 02/06/2015 ®Yes ❑ No 10/01/2019 Sewer Use Ordinance(SUO) 01/08/2013 ® Yes ❑ No 01/09/2013 ®Yes ❑ No Enforcement Response Plan(ERP) 06/01/2010 ®Yes ❑ No 07/02/2010 ®Yes ❑ No Long Term Monitoring Plan(LTMP) 10/07/2016 ®Yes ❑ No 11/04/2016 ® Yes ❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Leggett 142 12. Cardinal Containers 3.Tier Rack 30. IUP Number 0028 0010 0045 31. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ No ®Yes LI No 32. Permit Expiration Date 05/31/19 0.5/31/19 05/31//19 33. Categorical Standard Applied(I.E.40 CFR, Etc.)Or N/A 433 ---- 433 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 Last 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. ZYes❑No b.If No,is One Needed?(See Inspection Form from POTW) b. EYes ❑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❑NoZN/A ®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? N/A 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❑NoNN/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 lUs with Production based limits,does file include ❑Yes❑NoNN/A ❑Yes❑NoEIN/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 N/A 43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoNN/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 Penod, Was Enforcement Taken ❑Yes❑NoNN/A ❑Yes❑No®N/A ❑Yes❑No®N/A as Specified in the POTW's ERP(NOVs,Penalties,timing, etc.)? 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoZN/A ❑Yes❑No®N/A ❑Yes❑NoE 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❑NoNN/A b❑Yes❑No®N/A b❑Yes❑No®N/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes [Si No ❑ Yes ® No ❑ Yes ® No Requested Information For You? NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2 FILE REVIEW COMMENTS: a Tier Rack,a welding shop,previously had a problem with high copper in their process water. The facility no longer discharges to the POTW,but has the process water hauled away to be disposed of off-site. Manifests from the hauling events are sent to the POTW. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY 1 1 1 I I I I 1' 1 I I I 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: A very well run program. Requirements: Recommendations. NOD: ❑YES ® NO NOV: ❑ YES ® NO QNCR: ❑YES ® NO POTW Rating: Satisfactory X Marginal Unsatisfactory PCI COMPLETED BY: Jim Gonsiewski DATE: 0(r/ NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3