NC0025071_NOD-2020-PC-0095_20200305

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 5, 2020
Christopher Powell, Pretreatment Coordinator
PO Box 70
Eden, NC 27289-0070
SUBJECT: Pretreatment Compliance Inspection Report and Notice of Deficiency
NOD Tracking # NOD-2020-PC-0095
Town of Eden
NPDES# NCO025071
Rockingham County
Dear Mr. Powell:
On February 13, 2020, Paul DiMatteo of the Division of Water Resources, Winston-Salem
Regional Office conducted a Pretreatment Compliance Inspection at the above referenced
wastewater treatment system. The purpose of this inspection was to determine the effectiveness
of the Town's pretreatment program, which included: reviewing the files, POTW plant
performance, sampling and compliance judgement program, and adherence to the Enforcement
Response Plan.
Background
The Town operates one 13.5 MGD facility and has 3 significant industrial users (SIUs), 2 of
which are categorical.
POTW Interview
There have been no NPDES permit limit violations in 2019 and Mr. Powell indicated that he has
had no issues implementing the pretreatment program.
Please refer to the attached report for additional file review comments and requirements.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted for on March 9, 2017 and approved on
August 10, 2017. The next HWA is due on April 1, 2022.
The City's last Industrial Waste Survey (IWS) was submitted on November 20, 2015 and was
approved on December 15, 2015. The next IWS is due October 1, 2020. Mr. Powell said he
would send surveys out shortly.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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The last Long Term Monitoring Plan (LTMP) was submitted on August 29, 2017 and approved
on October 25, 2017.
The Sewer Use Ordinance (SUO) was approved on December 14, 2012.
The ERP was approved on February 6, 2020.
LTMP Review
The LTMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Karastan Rug (#1005), Weil Mcain (#1012) and Duke Energy (#1013)
revealed that monitoring data was well organized and violations were addressed in a timely
manner consistent with the ERP. The slug control plans were in good order.
Notice of Deficiency
During the inspection, Mr. Powell was not able to locate copies of approval letters for the most
recent Industrial Waste Survey, Karastan Rug and Weil McLain IUPs, and the Toxic Organics
Management Plan for Weil McLain. Additionally, the Inspector noted that phenol was not
analyzed by the POTW at Weil McLain. Mr. Powell said that the parameter was removed from
their LTMP; however, the IUP was not modified to reflect the removal.
The issues noted above collectively result in this Notice of Deficiency.
If you have any questions, please contact Paul DiMatteo at [phone] or
Paul.Dimatteo(ancdenr.gov; or our office at [phone].
Sincerely,
EDocuSigned<by:
LOw, -T ->mJtr
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: DWR Laserfiche Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Waterkesaurces
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Eden
2. Control Authority Representative(s): _Chris Powell
3. Title(s): Chief Operator/Pretreatment Coordinator
4. Last Inspection Date: _12/13/2017 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:
ICIS CODING
Main Program Permit Number
N I C 1 0 10 1215101711
MM/DD/YY
1021131201
Are Milestone Dates Being Met? ❑ YES ❑ NO
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?
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 ?
2
16. Number of CIUs in SNC? 11
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?
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 fox
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fox
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul
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
❑ YES ❑ NO
Limits: 0
Reporting: 0
Ilished: 0
None
❑ 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! Reviewed 12/20 DMR
26. If NO to 23 - 26, list violations None
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
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/9/2017
® Yes ❑ No
8/10/2017
® Yes ❑ No
4/1/2022
Industrial Waste Survey IWS
11/20/2015
® Yes ❑ No
12/15/2015
❑ Yes ® No
10/1/2020
Sewer Use Ordinance (SUO)
12/11/2012
® Yes ❑ No
12/14/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1/9/2020
® Yes ❑ No
2/6/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/29/2017
® Yes ❑ No
10/25/2017
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Karastan Rug ir 2. Duke Energy
3. Weil McLain
30. IUP Number
1005
1 1013
1012
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
9/30/2023
2/28/2021
7/31/2020
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
I N/A
423.16 =1
433.17
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?
® Yes ❑ No
®Yes ❑ No
®Yes ❑ No
36. a. Does the File Contain a 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
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. ❑Yes ®No
1b.[3Yes0No19
a. ®Yes ❑No
a. ❑Yes ®No
b. All Issues Resolved?
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 by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ Rol
® 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
EYes❑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❑NoON/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
0Yes0No[9
❑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 ❑ 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.pYes❑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
❑
Yes
®
No
I
❑
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.)?
11
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 Enforcement Orders?
a.❑Yes❑No®N/A
I
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No[9
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Yes ®No
❑ Yes ® No
® No
Requested Information For You?
FM
77es
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
- POTW also locally permits 2 IUs, Eden Custom Processing and Blue Ridge Plastics. They are inspected and given
monitoring requirements but no limits.
- Phenol was removed from POTW's LTMP in 2017. While reviewing Weil McLain's file it was noted that IUP was not
modified to remove the phenol monitoring requirement by either the POTW or SIU. POTW continued to require the SIU
to sample for phenol but did not complete its own sampling. The POTW should have either continued its own sampling or
removed the monitoring requirement in the IUP.
- IWS approval letter, DWR IUP approvals for Karastan Rug and Weil McLain, and the TOMP for Weil McClain were not
located during the inspection.
- Civil penalties are collected by the Town's finance office and a confirmation is made to Mr. Powell verbally. POTW should
ensure that documentation of penalty collection is available, e.g., noting a financial record number or ensuring that the
finance office keeps such records.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone:
MM/DD/YY
Title:
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:
None
OVERALL SUMMARY AND COMMENTS:
Comments: Missing documentation noted above was reportedly due to being unable to locate documents in the previous coordinator's
Requirements: Ensure documents are kept in an easily accessible manner.
Recommendations: _When modifying the LTMP to add or remove pollutants of concern, 11UPs should also be reviewed and modified as
necessary to ensure consistences
NOD: ® YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating: Satisfactory Marginal XXX UnSatisfactory
//
DOCUSigned by:
PCI COMPLETED BY: 1 .j Ash lzt.e- WSRO
ATE: 3/5/2020
Fl OUC2E5BB34D4...
NC DWR Pretreatment Compliance InspectionForm Updated December 2016 Page 3