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Home My WebLink AboutNC0024112_Compliance_20190130 ROY COOPER 'O � Governor �p �� MICHAEL S.REGAN ''•, '.- .. wN+ ° Secretary LINDA CULPEPPER NORTH CAROLINA Director Environmental Quality January 30, 2019 RECEIVED/DENR/DWR Misty Condor FEB 05 2019 Pretreatment Coordinator Water Resources City of Thomasville Permitting Section P.O. Box 368 - Thomasville,NC 27361 SUBJECT: Pretreatment Compliance Inspection (PCI) City of Thomasville NPDES#NC0024112 Davidson County Dear Ms. Condor: On December 19, 2018 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski of the Winston-Salem Regional Office. Ms. Misty Condor was present for the inspection. The purpose of this inspection was to determine the effectiveness of the Town's pretreatment program, which includes reviewing the files, POTW plant performance, industry monitoring data, and adherence to the enforcement response plan(ERP). Background ' This is a 6 MGD permitted facility. The City has five (5) Significant Industrial Users (SIUs), four _ (4) of which are categorical. The publicly owned treatment works (POTW) has had exceedances of BOD and TSS in 2018 due to hydraulic issues caused by the weather. POTW Interview There are no plant problems related to pretreatment issues and,other than BOD and TSS,there are no NPDES permit limit or monitoring violations recorded from February 2018 through November 2018. The facility is very well operated. Pretreatment Program Elements Review The Headworks Analysis (HWA) renewal was submitted on October 26, 2015. The HWA was approved on March 4, 2016. The next HWA is'due on October 1, 2020. The last Industrial Waste Survey (IWS) was submitted on July 3, 2015. The IWS was approved on September 11, 2015. The next IWS is due on April 30, 2020. North Carolina Department of Environmental Quality I Division of Water Resources D_E�.--) Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103 NORTH CAROLINA Depamnantof Emtroamental uucaty 336.776 9800 The Sewer Use Ordinance (SUO)was approved on March 25, 2013. The Enforcement Response Plan(ERP) was approved on October 9, 2008. The Long Term Monitoring Plan(LTMP) was approved on October 27, 2014. LIMP File Review The Long Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies. Industrial User Permit (IUP) File Review Three (3) of the five (5) Sills were in noncompliance in 2018. One (1) SIU (Custom Drum) was in significant noncompliance (SNC). Fines totaling$1,200 were assessed. A review of the file for Advance Materials Coating (AMC) (#0028) revealed that the monitoring data was well organized and compliant. A review of the file for Brasscraft. (#0008) revealed that the monitoring data was well organized and compliant. -A review of the file for McIntyre Metals (#0031) revealed that the monitoring data was well organized and compliant. The slug control plan for AMC (#0028)was in good order. The slug control plan for Brasscraft(#0008)was in good order. The slug control plan for McIntyre Metals (#0031) was in good order. Action Items No other action items were noted. The pretreatment program is considered satisfactory. Ms. Condor runs an excellent pretreatment program. If you have any questions please contact Jim Gonsiewski or me at(336) 776-9800. Sincerely, aet Sherri V. Knight, P Regional Supervisor Water Quality Regional Operations Section Division of Water Resources,NCDEQ—WSRO cc: PERCS Unit—Monti Hassan Central Files WSRO Files NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT Water Resources ENVIRONMENTAL OUALifY BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1 1. Control Authority(POTW)Name: Hamby Creek Wastewater Treatment Plant—City of Thomasville 2. Control Authority Representative(s): Misty Condor 3. Title(s):Laboratory Supervisor/ 4. Last Inspection Date: 02/15/2018 Inspection Type(Check One ® 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: Are Milestone Dates Being Met? ❑ YES ❑NO ICIS CODING Main Program Permit Number MM/DD/YY NICIO 10 12 1 4 11 1 1 12 J 12 119 I 18 I 7. Current Number Of Significant Industrial Users(SIUs)? 5 8. Number of SIUs With No IUP,or With an Expired IUP9 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? ' 1 12.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods? 1 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)? 4 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? BOD,TSS. This is a hydraulic (weather) issue 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:Custom Drum either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting: Custom Drum Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: Will be published 2/19 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 E NO Division Inspector,please verify yourself! 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 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 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) 10/26/2015 ® Yes ❑ No 03/04/2016 ®Yes ❑ No 10/01/2020 Industrial Waste Survey(IWS) 07/03/2015 ®Yes ❑ No 09/11/2015 ®Yes ❑ No 04/03/2020 Sewer Use Ordinance(SUO) 01/31/2013 ®Yes ❑ No 03/25/2013 ®Yes El No Enforcement Response Plan(ERP) 08/07/2008 ®Yes ❑ No 10/07/2008 ®Yes El No Long Term Monitoring Plan(LTMP) 09/19/2014 ®Yes ❑ No 10/24/2014 ®Yes ❑ No INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1.AMC 2.Brasscraft 3.McIntyre Metals 30. IUP Number 0028 0008 0031 31. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ No ®Yes ❑ No 32. Permit Expiration Date 01/31/22 01/31/22 06/30/22 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 ® Yes ❑ No ®Yes El No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ® Yes El 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. ZYes❑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)? _ 38. a. Does File Contain Original Permit Review Letter from the Division? a. ZYes❑No a. ZYes ❑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 El No ®Yes ❑ No its Sampling as Required by IUP,including flow? 40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ® Yes El No ®Yes ❑ No ®Yes El 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 Ills with Combined Wastestream Formula(CWF), does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoE1N/A file mclude process/dilution flows as Required by IUP? 42b.For categorical Ills with Production based limits,does file mclude ❑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 El 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__es 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? El 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,timing, etc.)? Fined Fined 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 MN/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 El Yes ® No El Yes ® No Requested Information For You? NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2 • FILE REVIEW COMMENTS: McIntyre Metals is currently updating its Slug/Spill Control Plan. The BOD and TSS exceedances were due to heavy rain. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY J I I I I I I I I L J I I l 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: i/ 3 Cori l NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3