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HomeMy WebLinkAboutNC0021636_Pretreatment Audit_20230810ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality August loth, 2023 Ms. Vicky Payseur, Pretreatment Coordinator P.O. BOX 1119 Lillington, NC 27546 Subject: Pretreatment Audit North Harnett Regional WWTP NPDES Permit No. NCO021636 Harnett County Ms. Payseur: A Pretreatment Audit of the North Harnett Regional WWTP's Pretreatment Program was conducted by Sharon Moran from this office on July 17, 2023. The purpose of this audit is to determine the effectiveness of the pretreatment program by reviewing various aspects of the program, which included files and records, industrial user inspections and monitoring data, data management procedures and adherence to the Enforcement Response Plan. The POTW's routine inspection at Bulldog Hose was observed. This inspection included Sharon Moran, Vicky Payseur, and Rusty Furtick, Plant Manager at Bulldog Hose. The North Harnett Regional WWTP continues to do an effective job of achieving the pretreatment program goals. The findings and comments noted during this inspection are provided in the enclosed copy of the audit report. There were no significant issues or findings noted during this inspection thus a response to this inspection report is not required. Thank you for your continued support of the North Carolina Pretreatment Program. If you should have any questions, please contact Sharon Moran at (910) 916-3489 or at sharon.moran@deq.nc.gov. Sincerely, DocuSigned by: bmjx 1 E4E1A9691DB248E... Mark Brantley, Assistant Regional Supervisor Water Quality Regional Operations Section Fayetteville Regional Office Division of Water Resources, NCDEQ Cc: Upload to Laserfiche D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301 NORTH CAROLINA - oeuaronemmemironmemaiauai\ p*O** 910.433.3300 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN 1 2 u 3 I NC0021636 111 121 23/07/17 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 09:OOAM 23/07/17 17/11/01 North Harnett Regional WWTP 607 Edwards Dr Exit Time/Date Permit Expiration Date Lillington NC 27546 01:OOPM 23/07/17 21/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Kenneth Wayne Fai1/0RC/910-893-2424/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Billy J Thomas,PO Box 1119 Lillington NC 275461119/Backup ORC/910-814-3042/ 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 Sharon Moran Docusigned by: DWR/FRO WQ/910-433-3300/ 8/14/2023 LvDIn, Aurm. Es2BE17E499D6943D... Signature of Man t'€AgftR%aiewer Agency/Office/Phone and Fax Numbers Date Mark Brantle A'" EVR/Division of Water Quality/910-433-3300 Ext.727/ 8/15/2023 E4P A9691 DB248E... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO021636 I11 12I 23/07/17 117 18 1,1 lul Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Enclosed, please find a copy of the Pretreatment Audit Form from the inspection conducted on July 17th, 2023. The Pretreatment Audit was conducted by Sharon Moran, Environmental Specialist, of the Fayetteville Regional Office with Vicky Payseur, Pretreatment Coordinator with N. Harnett Regional WWTP. This PT audit report indicated that the N. Harnett Regional WWTP Pretreatment Program did meet the pre-treatment requirements as outlined in 15A NCAC 2H .0900 Page# Permit: NC0021636 Inspection Date: 07/17/2023 Owner -Facility: North Harnett Regional WWTP Inspection Type: Pretreatment Audit Yes No NA NE Page# NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Water Resources ENVIRONMENTAL QUALITY Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: N. Harnett 2. Control Authority Representative(s): Vicky Payseur 3. Title(s): North Harnett Regional WWTP Pretreatment Coordinator 4. Address of POTW: Mailing P.O. Box 1119 City Lillington Zip Code 27546 Phone Number (910) 893-2424 ext 5481 Fax Number (910) 814-8284 E-Mail vpayseur(a,harnett.org 5. Audit Date 07/17/2023 6. Last Inspection Date: 07/22/2021 Inspection Type: ❑ PCI ® Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No If No, Explain. 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No If Yes, Explain. 9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA Parameters Covered Under Order ICIS Coding Main Program Permit Number INIC101OI2 11 16 13 16 MM/DD/YY 17 117123 10: Current Number of Significant Industrial Users (SIUs)? .11....Num..ber...of..SIUs. ..with.No I.UP, or with an Expired IUP? ...................................... 12: Number of SIUs Not Inspected by POTW in Last Calendar Year? ........................................................................................................ 13 : Number of SIUs Not Sampled by POTW in Last Calendar Year? .................................................................................................. 14: Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods? 15: Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? ...................................................................... 16. Number of SIUs in SNC with Pretreatment Schedule? ................................................................................................................................................................................................... . 17. Number of SIUs on Schedules? ................................................................................................................................................................................................... . 18: Current Number of Categorical Industrial Users (CIUs)? 19. Number of C11tJs in SNC? ................................................................................................................................................................................................... . 1 0 0 0 0 0 0 0 1 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element in their File, complete with all supporting documents and 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) 08/06/2018 ® Yes ❑ No 10/17/2018 ® Yes ❑ No 07/01/2023 Industrial Waste Survey (IWS) 06/24/2019 ® Yes ❑ No 08/26/2019 ® Yes ❑ No 02/01/2024 Sewer Use Ordinance (SUO) 11/16/2011 ® Yes ❑ No 12/01/2011 ® Yes ❑ No Enforcement Response Plan (ERP) ❑ Yes ❑ No 12/13/2001 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 11/15/2018 ® Yes ❑ No 03/05/2019 ❑ Yes ❑ No Legal Authority (Sewer Use Ordinance-SUO) 21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? ® Yes ❑ No If yes, Please list these towns and/or areas. Angier, Fuquay 22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA A copy, if not already submitted, should be sent to Division. 23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA If yes, Explain. 24. Date of Last SUO Adoption by Local Counci112/05/2011 25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 26. Did you send a copy of the ERP to your industries? ® Yes ❑ No If no, POTW must send copy within 30 days. 27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc? ❑ Yes ® No If yes, Explain. 28. List Industries under a Schedule or Order and Type of Schedule or Order N/A Resources 29. Please Rate the Followine: S=Satisfactory M=Mareinal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program ®S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and ®S ❑M ❑U Emergencies Access to Operable Sampling Equipment ®S ❑M ❑U Availability of Funds if Needed for Additional Sampling and/or Analysis ®S ❑M ❑U Reference Materials ®S ❑M ❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) ®S ❑M ❑U Computer Equipment (Hardware and Software) ®S ❑M ❑U NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Established procedures and use of Microsoft Office is adequate. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Funding is budgeted from Harnett Regional Water Public Perception/ Participation 32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? ❑ Yes ® No If yes, Explain. 33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ❑ No If yes, Explain procedure. If no, how would the request be addressed? Request would be sent to director of Harnett Regional Water 34. Has any industry ever requested that certain information remain confidential from the public? ® Yes ❑ No If yes, Explain procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential from public. If no how would the request be addressed? Industry requested confidentiality based on production secrets, files were kept locked in the pretreatment office. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No 36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No 37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No N/A Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Harnett County Planning Department after POTW specifically requested notification due to lack of grease trap installations in new restaurants, touring 39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an SIU?) Have industries fill out industrial use permit, if pond gets high, high water usage. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ❑Yes ®No If Yes, How many are there? Please list each site and how it is permitted, if applicable. 41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) Flow meter at acceptance point. 43. How does the POTW allocate its loading to industries? Mark all that apply ❑ Uniform Limits ❑ Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ® Other Explain Other: NPDES Limits, Local Limits/HWA 44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No If yes, what parameters are over allocated? 45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.) 46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No If yes, what percentage of each parameter 10% 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No If yes, Explain. 48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants listed on the application limited; categorical parameters; NPDES Pollutants of Concern) NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 Use HWA/AT to determine possibility of plant inhibition. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. POTW NPDES limits, Categorical Industries, Changing requirements. Permit Compliance 50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No If yes, which industries? What was (will be) the outcome of the adjudication? 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting requirements, and permit conditions, as well as for SNC. Use the PAR sheet to determine SNC, Based on permit 52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, does the POTW form include all Division data? ❑ Yes ❑ No 53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No If no, Explain. 54. What criteria are used to determine if a slug/spill control plan is needed? Chemicals onsite and reasonability to spill. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Review plan for contact information, procedures 56. How does the POTW decide where the sample point for an SILT should be located? End of process, below all treatment processes, safety 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Standard location, walkthrough with SIU, no staff changes, shadowing, observation 58. Who performs sample analysis for the POTW for Metals Wavpoint Analytical Conventional Parameters Wavpoint Analytical Organics Wavpoint Analytical *Cameron Testing performs uncontrollable testing and testing for Bulldog Hose 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Verify that the information is correct for information and samples, sign and date. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA) 60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO 60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO *kept eDMR reports, not separate table 60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself. 60e. 60f. If NO to any above, list violations Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: 61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No If no, who completes your HWA? Phone (_) -- 62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No (Currently in the middle of) If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change ❑More LTMP data available ❑Resolve over allocation 05 year expiration ❑Other Explain. 63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through ❑Sludge Quality NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No Explain. Unneeded Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? Expansion planned in approximately two years. INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Bulldog Hose 2. 3. 67. IUP Number 0003 68. Does File Contain Current Permit? ® Yes ❑ No ❑ Yes ❑ NoI ❑ Yes ❑ No 69. Permit Expiration Date 5/31/25 70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A 428.6/463 71. Does File Contain Permit Application Completed Within One Ycar Prior ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 72. Does File Contain Inspection Completed Within Last Calendar Year? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 73. a. Does File Contain Slug/Spill Control Plan? a. ®Yes ❑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 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Yes❑NoON/A P ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan TOMP ? 75. a. Does File Contain Original Permit Review Letter from 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 76. During Most Recent Semi -Annual Period, Did POTW Complete its ® Yes ❑ No]1 ❑ Yes ❑ No ❑ Yes ❑ No Sampling as Required by IUP, including Flow? 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No 11 ❑ Yes ❑ No ❑ Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, including Flow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A time? 80a. For categorical IlUs with Combined Wastestream Formula (CWF), does ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 80b. For categorical IUs with Production based limits, does file include ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 81. During Most Recent Semi -Annual Period, Did POTW Identify All FN -Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Limits Non -Compliance from Both POTW and SIU Sampling? 82. During Most Recent Semi -Annual Period, Did POTW Identify All ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Re ortin Non -Compliance from SIU Sampling? 83. a. Was 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 and obtain results within 30 days of c.❑Yes❑No®N/A becomingaware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A 84. During Most Recent Semi -Annual Period, Was SIU in SNC? ❑ Yes ® No 11 ❑ Yes ❑ No 11 ❑ Yes ❑ No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Specified in POTW's ERP OVs, Penalties, timing, etc.)? 86. Does File Contain Penalty Assessment Notices? ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 88. a. Does 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 89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No Information For You? FILE REVIEW COMMENTS: NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY I N I C 1 0 10 12 11 16 13 16 I 7 1171231 1. Industry Inspected: Bulldog Hose 2. Industry Address: 141 Junny Rd Angier NC 3. Type of Industry/Product: Rubber/Categorical 428.6/463 4. Industry Contact: Rusty Furtick Title: Plant Manager Phone: 712-655-9288 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: Audit SUMMARY AND COMMENTS: Audit Comments: Requirements: Recommendations: Please resubmit your most up-to-date ERP to the Division to ensure a copy is on file. NOD: ❑ Yes ❑ No NOV: ❑ Yes ❑ No QNCR: ❑ Yes ❑ No POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ DocuSigned by: Audit COMPLETED BY:F�Lvbvu kbrm. DATE: 8/14/2023 2BEWE499D6943D... Sharon Moran, FRO Regional Office NC DWR Pretreatment Audit Form Revised: December 2016 Page 6