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HomeMy WebLinkAboutNC0047384_202307PCI_20230727NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT Water Resources ENVIRONMENTAL QUALITY BACKGROUND INFORMATION 1Comnlete Prior To PCI: Review ProLyram Info Database Sheets 1. Control Authority (POTW) Name: _Ci of Greensboro 2. Control Authority Representative(s): _Amy Varinoski, Alicia Goots, Bill Burdick, Julie Greene, Martie Groome 3. Title(s): Pretreatment Coordinator, Lab & PT Services Superintendent, PT Compliance Specialist, Lab & PT Specialist, Consultant 4. Last Inspection Date: _08/02/2022 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 NIC101014171318141 1 1 1 7. Current Number Of Significant Industrial Users (SIUs)? 29 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? F 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? 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 ? 21 16. Number of CIUs in SNC? 2 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? 1,4-dioxane traced to Hallstar — cease discharge from that process, NOV, SNC, civil penalty, & public notice. CBOD & NH3-N violations result of an accidental discharge from Ecolab — issued NOV, SNC, civil penalty, & public notice. 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? 19. Which Industries have been in SNC for Limits or Reporting during SNC for either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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? 21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ® YES [-]NO 1,4-dioxane SOC compliance value (April 5, 2022) CBOD, NH3-N (May 2022) ® YES ❑ NO See response to #17 Limits: Reporting: 1 blished: 0 N/A ❑ 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 Division Inspector, please verify yourself! 26 27 IfNO to 23 - 26, list violations Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1 If yes, which ones? Eliminated: Added: 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) 2/15/2022 ® Yes ❑ No Pending ❑ Yes ❑ No Pending Industrial Waste Survey (IWS) 9/30/2019 ® Yes ❑ No 2/12/2020 ® Yes ❑ No 9/30/2024 Sewer Use Ordinance (SUO) 4/13/2023 ® Yes ❑ No Pending ❑ Yes ❑ No N/A Enforcement Response Plan (ERP) 1 3/01/2022 ® Yes ❑ No Pending ❑ Yes ❑ No N/A Long Term Monitoring Plan (LTMP) 1 11/13/2019 ® Yes ❑ No 2/11/2020 ® 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. Hallstar 2. Ecolab 3. Piedmont Plating 30. IUP Number P025 P078 I P075 31. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ NoI ® Yes ❑ No 32. Permit Expiration Date 8/31/23 8/31/23 8/31/23 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 414 417 413 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? I ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? a. ❑Yes ENo a. ®Yes ❑No a. ❑Yes ENo b. If No, is One Needed? See Inspection Form from POTW b. ❑Yes ENo b. ❑Yes ❑No b. []Yes ENo 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑No®N/A 11 ❑Yes❑NoON/A ®Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. EYes ❑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 ElNo its Sampling as Required b IUP, includingflow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ I ® 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❑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❑No®N/A file include process/dilution flows as Required b IUP? 42b. For categorical IUs with Production based limits, does file include 0Yes0No[9 [TT;❑No®N/Ares[]NoZN/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? 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 Re ortin Non-Com liance 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 of SIU limit violations in the POTW's sampling of the SIU? c.❑Yes❑No®N/A 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 11 [—]Yes ❑ No ❑ Yes ® No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes❑No®N/A ❑Yes❑NoEN/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❑No❑N/A ®Yes❑No❑N/A ❑Yes❑NoEN/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 Yes❑No®N/A FbOYesOMON/A a.❑Yes❑No®N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No®N/A NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ❑ Yes ®No ❑Yes ®No ❑Ycs ®No FILE REVIEW COMMENTS: Files and in order. No issues found during inspection. Note: Ecolab is not required to have a spill/slug plan for WWTP. Plan is for storm water purposes. 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: Phone: Fax: Title: 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: _Ms, Varinoski and staff run and excellent pretreatment program. Requirements: Recommendations: NOD: ❑ YES ®NO NOV: ❑ YES ®NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory X Marginal UnSatisfactory PCI COMPLETED BY: Tricia Lowery & Jesse Barnes DATE: 7/20/2023 NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3