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Home My WebLink AboutNC0020664_PCI_20190619 June 19, 2019 Scott Webber, Town Manager Town of Spindale PO Box 186 Spindale, NC 28160 SUBJECT: Pretreatment Compliance Inspection Report Spindale WWTP NPDES WW Permit No. NC0020664 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted a Compliance Inspection of the Spindale WWTP’s Pretreatment Program on 6/11/2019. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Pretreatment Compliance Inspection Report” (PCI). Please note the recommended submittal date for the LTMP update in the attached PCI report. There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to me at 828-296-4500 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist I Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: PCI Report EC: WQS-ARO Server LF-PERCS G:\WR\WQ\Rutherford\Wastewater\Municipal\Spindale WWTP 20664\Pretreatment\20190619_NC0020664_PCI DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NC0020664 19/06/11 P S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Spindale WWTP Ecology St Spindale NC 28160 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 02:30PM 19/06/11 15/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Robert Eugene Lipscomb/ORC/828-286-3407/ Other Facility Data 04:40PM 19/06/11 18/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Robert Eugene Lipscomb,132 Wilkins St Forest City NC 28043//828-286-3407/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Pretreatment Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Mikal Willmer Division of Water Quality//828-296-4686/ Vivien Zhong Pretreatment Unit//919-807-6310/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D 6/19/2019 6/19/2019 NPDES yr/mo/day 19/06/11 Inspection Type P3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer, with the Asheville Regional Office, and Vivien Zhong, with the Central Office, conducted a Pretreatment Compliance Inspection of the Town of Spindale's Pretreatment Program under Permit No. NC0020664. The inspection was conducted to determine whether the program is being managed and maintained in compliance with all Pretreatment regulations. Robert Lipscomb (Backup ORC) was present and assisted in the inspection. Overall the program appeared to be well maintained and all sampling is being reported on Monthly DMRs. SIUs are sampling in accordance with their IUPs. Refer to the attached PCI Report for additional information. NC0020664 17 (Cont.) Page#2 DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D Permit:NC0020664 Inspection Date:06/11/2019 Owner - Facility: Inspection Type: Spindale WWTP Pretreatment Compliance Yes No NA NE Page#3 DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D NC 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: Spindale WWTP 2. Control Authority Representative(s): Robert Lipscomb 3. Title(s): Back-up ORC 4. Last Inspection Date: 02/15/2017 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 ICIS CODING Main Program Permit Number MM/DD/YY | N | C | 0 | 0 | 2 | 0 | 6 | 6 | 4 | | 06 | 11 | 19 | 7. Current Number Of Significant Industrial Users (SIUs)? 3 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? 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? 0 14. Number of SIUs on Schedules? 0 15. Current Number Of Categorical Industrial Users (CIUs)? 1 16. Number of CIUs in SNC? 0 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 pH & DO due to upgrades at facility. 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: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? N/A 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 (see below) 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 (see below) 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: DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D 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) 03/11/16 Yes No 06/06/16 Yes No 12/01/20 Industrial Waste Survey (IWS) 01/03/19 Yes No 01/10/19 Yes No 12/31/23 Sewer Use Ordinance (SUO) 12/31/12 Yes No 01/09/14 Yes No N/A Enforcement Response Plan (ERP) 12/05/13 Yes No 01/09/14 Yes No N/A Long Term Monitoring Plan (LTMP) 10/27/04 Yes No 11/22/04 Yes No N/A ________________________________________________________________________________________________________________ INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name 1. Timken 2. Ultimate Textile 3. Spindale Mills 30. IUP Number 004 008 003 31. Does File Contain Current Permit? Yes No Yes No Yes No 32. Permit Expiration Date 6/30/23 6/30/23 6/30/23 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 N/A N/A 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 N/A a. Yes No b. Yes No N/A a. Yes No b. Yes No N/A 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 Collection? Yes No N/A Yes No N/A Yes No N/A 50. a. Does the File Contain Any Current Enforceme nt 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: 7488F844-BFC2-4A4B-BFFD-00343D07688D NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3 FILE REVIEW COMMENTS: 22. Resolved sampling issues with Spindale Mills. Spindale is currently sampling more frequently than required. LTMP will be updated within system to reflect the approved plan from 2012 . Spindale should update their LTMP by August 31, 2019. 23. Data was kept in separate binders for each facility. Mr. Lipscomb indicated some information was maintained on the computer . Recommend organizing all files in a central location for current and future staff. 36. If not already on-site, facility staff should obtain copies of SIU’s spill control plans for reference. IU inspection indicate spill control plans were reviewed at the time of the inspections. 37. Did not see a Toxic Organic Management Plan for Timken in binder; however, may be in different locations. 44. Spindale Mills was found to be in SNC for a Limit Violation on 12/27/18. Facility resampled 1/17/19. Water Tech is now sa mpling for Spindale Mills. An NOV was sent to Spindale Mills and a notice was posted in the paper. No further action was taken. No ongoing issues reported. INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY | | | | | | | | | | | | | | 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: An industry inspection was not conducted. Reviewed IU inspections completed within the last year by the pretreatment coordinator. No issues reported during inspections. Spindale appears to be using an appropriate inspection form. OVERALL SUMMARY AND COMMENTS: Comments: LTMP: recommended this be updated to reflect quarterly monitoring. Currently the facility is sampling more than required. Recommend the Town review the Sewer Use Ordinance to ensure information is still applicable and part of the Town’s current practices. Maintain copies of the SIUs spill control plans on file for reference, if not already on -site. Recommend gathering all facility information in a central location for current and future staff. Requirements: Facility should update LTMP by August 312019. LTMP needs to be updated to reflect current sampling practices and to remove industries no longer in the current program. Recommendations: File all pretreatment information in a central location for current and future staff . As a reminder, the HWA is due December 2020. DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4 NOD: YES NO NOV: YES NO QNCR: YES NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Mikal Willmer & Vivien Zhong DATE: 6/11/2019 DocuSign Envelope ID: 7488F844-BFC2-4A4B-BFFD-00343D07688D Certificate Of Completion Envelope Id: 7488F844BFC24A4BBFFD00343D07688D Status: Completed Subject: Please DocuSign: 20190619_NC0020664_PCI.inspect.pdf, 201904611_NC0020664_PCI.docx, 20190619_NC0... Source Envelope: Document Pages: 8 Signatures: 3 Envelope Originator: Certificate Pages: 2 Initials: 0 Mikal Willmer AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Jun 19, 2019 | 09:15 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Jun 19, 2019 | 09:32 Viewed: Jun 19, 2019 | 09:33 Signed: Jun 19, 2019 | 09:33 Electronic Record and Signature Disclosure: Not Offered via DocuSign G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 149.168.204.10 Sent: Jun 19, 2019 | 09:33 Viewed: Jun 19, 2019 | 09:36 Signed: Jun 19, 2019 | 09:37 Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Jun 19, 2019 | 09:33 Certified Delivered Security Checked Jun 20, 2019 | 16:17 Signing Complete Security Checked Jun 20, 2019 | 16:17 Envelope Summary Events Status Timestamps Completed Security Checked Jun 20, 2019 | 16:17 Payment Events Status Timestamps