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HomeMy WebLinkAboutNC0020737_Inspection_20190123ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Richelle Meek WWTP Superintended/Pretreatment Coordinator City of Kings Mountain Post Office Box 429 Kings Mountain, North Carolina 28086 Dear Ms. Meek: NORTH CAROLINA Environmental Quality 23 January 2019 Subject: Pretreatment Compliance Inspection City of Kings Mountain NPDES Permit No. NCO020737 Cleveland County Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of Kings Mountain's approved Industrial Pretreatment Program on January 16, 2019, by Mr. Wes Bell of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell(c�r�,ncdenr.gov. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report D Q � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROLINA Da"MoM a enWmn�bl mwnq 704,663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION: 1. Control Authority (POTW) Name: City of Kings Mountain 2. Control Authority Representative(s): Richelle Meek, Jason Davis 3. Title(s): WWTP Superintendent/Pretreatment Coordinator, Lab Tech/Pretreatment Analyst 4. Last Inspection Date: 7/19/17 Inspection Type: ❑ 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: SOC WQ S16-001 Ad I; Prepare and issue modified SIU Permit by 3/31/16 (met); Quarterly status reports by (January 1, April 1, July 1, October 1); Attain Compliance with NPDES Limit (thallium) by 8/31/20. Are Milestone Dates Being Met? ® YES ❑ NO ❑ NA ICIS CODING Main Program Permit Number MM/DD/YY NCO020737 01/16/19 7. Current Number Of Significant Industrial Users (SIUs)? 1 6 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 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 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)? 6 16. Number 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? See Comments 18. Since the Last PCI, has the POTW had any Problems Related to an Industrial U YES IZI 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 N/A either of the Last 2 Semi -Annual Periods? Not Been Published for Not Published: N/A Public Notice?(May refer to PAR if Excessive SIUs in SNC) 20. Which Industries are on Compliance Schedules or Orders? For all SlUs on an N/A 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 II U 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 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 7/25/07 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW: Program Element NCO020737 Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 12/2/15 ® Yes ❑ No 4/21/16 ® Yes ❑ No 9/1/20 Industrial Waste Survey IWS 12/18/14 ® Yes ❑ No 12/1/15 ® Yes ❑ No 12/1/19 Sewer Use Ordinance SUO 10/4/13 ® Yes ❑ No 10/10/13 ® Yes ❑ No Enforcement Response Plan (ERP) 1/10/14 ® Yes ❑ No 3/11/14 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 12/2/15 ® Yes ❑ No 4/1/16 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW: 29. User Name = 1. Buckeye 2. KMI 3. CFC 30. IUP Number 015 031 333 31. Does File Contain Current Permit? ® Yes ❑ I ® Yes ❑ I ® Yes ❑ No 32. Permit Expiration Date 7/29/21 6/15/20 2/17/19 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 433 433 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No FMTes ❑ No ® Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? I ® Yes ❑ No ® Yes ❑ No 11 ® Yes ❑ No 36. a. Does the File Contain aSlug/Spill Control Plan? a. EYes ❑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 P ®Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes ❑No a. EYes []No a. EYes ❑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 b IUP, includingflow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? I ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 41a. 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❑NoEN/A file includeprocess/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include 0Yes0No[9 FEVc;❑No®N/A ❑Yes❑NoEN/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoENA ❑Yes❑No®N/A ❑Yes❑NoEN/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoEN/A ®Yes❑No❑N/A ❑Yes❑NoEN/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. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No 11 ❑ Yes ® No ❑ Yes ® No 46. 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, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoNN/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A 49. 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 50. 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 7/25/07 Page 2 FILE REVIEW COMMENTS: 17. NPDES Effluent Limit Violations: June 2017 - Arsenic (daily maximum and monthly average) and TSS (weekly average); July 2017 — Arsenic (daily maximum); September 2017 — Ammonia (weekly and monthly average); May 2018 — Arsenic (daily maximum and monthly average); and September 2018 — Ammonia (monthly average). 25. The July 2018 and October 2018 edmrs will be revised to properly report the influent and effluent low level mercury result (not in the Comments Section) and effluent cadmium result (July 2018 edmr). 28. An effluent mercury limit became effective in the POTW's NPDES Permit on 1/1/2019. The POTW is in the process of submitting an updated HWA to include the mercury limit and site specific removal rate. 35. The POTW performed SIU inspections on 3/15/18 (KMI), 7/13/18 (Buckeye), and 3/13/18 (CFC). 39. The POTW's on -site laboratory performs BOD, TSS, ammonia, and pH analyses. Shealy Environmental Services, Inc. has been contracted to perform the analyses of all remaining LTMP parameters. 41 a. KMI contracts Pace Analytical Services, Inc. to perform analyses. Buckeye and CFC both contract PAR Laboratories, Inc. to perform analyses. 43b/46. KMI was issued a NOV for the failure to meet IUP detection levels for thallium and chloride. SUMMARY AND COMMENTS: The POTW must ensure that all IUP and LTMP detection levels are adhered to. The updated HWA (mercury) should be submitted to the PERCS Unit by February 1, 2019. The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly implemented. NOD: ❑ YES ®NO NOV: ❑ YES ®NO QNCR: [—]YES ®NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory_ ❑ E�_,96DWGC3437 cuSigneddby: PCI COMPLETED BY: ... DATE: January 23, 2019 Wes Bell, Mooresville Regional Office DocuSigned by: _Wlav 1/23/2019 A14CC681AF27425... NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3