NC0021504_Compliance Evaluation Inspection_20200820

ROY COOPER
Governor
MICHAEL S. REGAN
secretary
S. DANIEL SMITH
Dlrector
Brandon Holland
Town of Biscoe
110 W Main St
Biscoe, NC 27209
NORTH CAROLINA
Environmental Quality
August 20th, 2020
SUBJECT: Pretreatment Compliance Inspection Report
Biscoe WWTP
NPDES WW Permit No. NCO021504
Montgomery County
Dear Permittee:
Enclosed please find a copy of the Pretreatment Compliance Inspection (PCI) form from the inspection
conducted on 7/27/2020. The Pretreatment Compliance Inspection was conducted by Kristen Slodysko,
an Environmental Specialist from the North Carolina Division of Water Resources (DWR) Fayetteville
Regional Office. The cooperation of Lisa Osthues, Pretreatment Consultant, and Sam Stewart, Public
Works Director, was greatly appreciated.
The findings and comments noted during this inspection are provided in the enclosed copy of the
inspection report entitled "Pretreatment Compliance Inspection Report".
Issues:
The POTW measures pH and temperature at both of its Significant Industrial User (SIU) plants
(Carolina Dairy and AAM Castings). Temperature and pH readings taken by the POTW at the SIU are
reported to the Pretreatment Coordinator via email. However, field sheets and original documentation
for pH and temperature readings were not available for review on the day of inspection. All records of
monitoring activities and results should be retained for a minimum of three years as per NPDES
Standard Conditions Part IV, Section D (12). The POTW reports that they have prepared a field sheet
template, which will be used to record SIU pH and temperature measurements at future sampling
events.
IUP 001 Part I, Section F requires the POTW to monitor flow while sampling at Carolina Dairy. The
POTW reports that they have not been recording flow during sampling events. Please ensure that
flow data is recorded by the POTW during future sampling events at the SIU, as per the IUP.
North Cam ins Depart ment of Environmenta! Qua4y I Division of Water Resources
Fayettevi!e Reg:oral 4rf:oe 1225 Green Street, Suite 714 1 Fayettem i!e, North Caro l;na 28301

• The POTW does not have a copy of the permit application for Carolina Dairy (IUP 001). The permit
application was originally handled by LKC Engineering. The POTW will follow-up with LKC Engineering
and request a copy of the permit application.
• In several instances the POTW did not conduct the STMP monitoring according to their Division
approved plan:
o According to the Short Term Monitoring Plan (STMP), sampling was scheduled to take place
quarterly from the second quarter of 2018 through the first quarter of 2019. However, in 2018
sampling only occurred in the third quarter of the year. In order to complete the necessary
sampling for the Head Works Analysis (HWA) the Municipal Unit approved a modified plan with
sampling in January, February, and March 2019. The modified STMP was completed in 2019
and the HWA was approved on 8/20/2019.
o On several occasions (March 2019 and April 2019), mercury analysis did not meet the minimum
detection limit required by the STMP. The POTW reports that the Municipal Unit was notified of
this issue.
o Cyanide data was not reported on the DMR in several instances (February 2019 and April 2019).
The POTW notified the inspector that the cyanide data was missing and indicated that an
amended DMR would be submitted. Please submit updated DMRs to include cyanide effluent
data for February 2019 and April 2019 within 30 days of receiving this letter.
Please ensure that the Division approved STMP is properly implemented by sampling at the correct
frequencies, meeting minimum detection limits, and reporting all effluent data on monthly DMRs as
per NPDES Standard Conditions Part IV, Section D 3 and 15A NCAC 02H.0905.
Comments:
In 2019 Carolina Dairy had multiple limits violations for BOD, TSS, and pH. The SIU was in Significant
Non -Compliance (SNC) for BOD for both 6 month periods of the year. Carolina Dairy continued to
have violations for TSS, BOD, and pH in the first half of 2020. On June 9t" 2020, the Town of Biscoe
signed a Consent Order and Compliance Schedule with Carolina Dairy to help them achieve
compliance with Industrial User Permit (IUP) limits. The POTW reports that Carolina Dairy has taken
steps to reduce violations. These steps include providing more training for the treatment operator
and installing an inline pH meter for better process control of treatment units. As per the Compliance
Schedule, Carolina Dairy must prepare and submit a report to the Town of Biscoe by August Th 2020,
which outlines, "changes or additions to the current pretreatment process necessary to achieve
compliance with permit limitations, IUP, Part 1 Section F." Carolina Dairy must achieve compliance
with final IUP limits by December 15t" 2020.
• The POTW received an NOV on May 19th, 2020 for failure to adequately implement its Enforcement
Response Plan (ERP) during the 2019 PAR year. In the first six-month period of 2020, the POTW
appears to have taken steps to implement the ERP including initiating a Compliance Schedule with
Carolina Dairy and issuing NOVs and Penalty Assessments.
• Monitoring records submitted by the SIU to the POTW appeared complete including analytical data,
flow, and TTO certifications. Please include in the facility's pretreatment file the date that the records
were received to help establish if reporting deadlines were met.
North Cz ra Depart ment of Enwroa menta! Qua I I Division of Water Resources
Fayettev -e Reg:ora l 4rf:oe 1 225 Green Street, Suite 714 1 Fsyettem i!e, North Caro l;na 28301

• An updated Industrial Waste Survey was submitted to the Municipal Unit on 6/15/20. The POTW is
waiting for the document to be approved by the Municipal Unit.
If you should have any questions, please do not hesitate to contact Kristen Slodysko with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at
[e-mail].
Sincerely,
IDocuSigned by:
V1S{t,In, �(, j, S6 8/20/2020
2CDAF4695DFF454...
Kristen Slodysko, Environmental Specialist
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Pretreatment Compliance Inspection Report
North Carolina Department of Environmental Quality I Division of Water Resources
Fayettevifle Regionsi Dffice 1 225 Green Street, Suite 714 1 Fayetteville, North Carofna 25301
910433 3390

No rth Carolina Depart rnent of Envconrnental Quality I Oiuision of Water Resources
Fayetteviffe Regionsi Office 1225 Green Street, Suite 714 1 Fayetteville, North Carofna 25301
910433 3390

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVAL I TV
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority(POTW)Name: Town of Biscoe, WWTP
2. Control Authority Representative(s): Lisa Osthues, Sam Stewart
3. Title(s): Pretreatment Consultant, Public Works Director
4. Last Inspection Date: 3/20/2018 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:
ICIS CODING
Main Program Permit Number
INIC101012111510141
MM/DD/YY
I7 1 24I20I
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)?
2
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?
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?
1
14. Number of SIUs on Schedules?
1
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
18
Addressed?
Total Ammonia (monthly) 3/31/20
Fecal coliforms (weekly) 2/15/20, 11/9/19, 6/8/19
Toxicity Failure: 4/2020, 5/2020.
The facility reports that the limits violations were not industry related. The toxicity test
failures were due to an issue with the chlorine feed. The POTW has since had a passing
Toxicity Test.
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?
A pump station malfunctioned due to break -through from the MBBR treatment unit at
Carolina Dairy. Media escaped the MBBR unit and traveled through the sewer to the pump
station. Carolina Dairy has now installed screens on the MBBR outflow to retain all media.
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)
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

20. Which Industries are on Compliance Schedules or Orders? For all SIl
Order, Has a Signed Copy of the Order been sent to the Division?
Carolina Dairy is on a Schedule of Compliance (SOC). The POTW has se
signed copy of the SOC to the Division.
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If
Which 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 ® NO Division Inspector, please verify yourself
26. If NO to 23 - 26, list violations:
• The STMP outlined that sampling should occur from the 2nd quarter of 2018 through the first quarter of2019. The POTW did not meet
the original sampling dates listed in the STMP. The Municipal Unit allowed the facility to conduct an alternative monitoring plan,
which the facility completed in January, February, March, and April of 2019.
• Cyanide data was missing from the DMR for 4/19 and 12/19.
• The mercury detection limit on 3/19 and 4/19 did not meet the minimum detection limit listed in the STMP.
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 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)
5/22/19
® Yes ❑ No
8/20/19
® Yes ❑ No
4/30/24
Industrial Waste Survey (IWS)
6/15/20
® Yes ❑ No
6/3/16
❑ Yes ® No
Sewer Use Ordinance (SUO)
7/23/14
® Yes ❑ No
7/28/14
® Yes ❑ No
Enforcement Response Plan (ERP)
1/18/16
® Yes ❑ No
4/12/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1/15/20
® Yes ❑ No
2/14/20
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Carolina Dairy 2. AAM Castings
3.
30. IUP Number
001
002
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
❑ Yes ❑ No
32. Permit Expiration Date
8/15/2021
8/15/2021
33. Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A
433
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 ❑ N=ol
® Yes ❑ No 11
❑ 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[g
®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
a. ®Yes ❑No
I
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 ElNo
ElYes ❑ No
its Sampling as Required b IUP, includingflow? Flow is missing
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
I ® Yes ❑ No 11
❑ 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 b IUP, includingflow?
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
1
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑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 ❑ 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.❑YesgNo❑N/A
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?
®
Yes
❑
No 11
❑
Yes
®
No 11
❑
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.)?
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
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
❑ Yes ® No
❑ Yes ❑ No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

FILE REVIEW COMMENTS:
The POTW measures pH and temperature at both of its Significant Industrial User (SIU) plants (Carolina
Dairy and AAM Castings). Temperature and pH readings taken by the POTW at the SILT are reported to the
Pretreatment Coordinator via email. However, field sheets and original documentation for pH and temperature
readings were not available for review on the day of inspection. All records of monitoring activities and results
should be retained for a minimum of three years as per NPDES Standard Conditions Part IV, Section D (12).
The POTW reports that they have prepared a field sheet template, which will be used to record SIU pH and
temperature measurements at future sampling events.
• IUP 001 Part I, Section F requires the POTW to monitor flow while sampling at Carolina Dairy. The POTW
reports that they have not been recording flow during sampling events. Please ensure that flow data is recorded
by the POTW during future sampling events at the SIU as per the IUP.
• The POTW does not have a copy of the permit application for Carolina Dairy (IUP 001). The permit
application was originally handled by LKC Engineering. The POTW will follow-up with LKC Engineering
and request a copy of the permit application.
In several instances the POTW did not conduct the STMP monitoring according to their Division approved
plan:
o According to the Short Term Monitoring Plan (STMP), sampling was scheduled to take place
quarterly from the second quarter of 2018 through the first quarter of 2019. However, in 2018
sampling only occurred in the third quarter of the year. In order to complete the necessary sampling
for the Head Works Analysis (HWA) the Municipal Unit approved a modified plan with sampling in
January, February, and March 2019. The modified STMP was completed in 2019 and the HWA was
approved on 8/20/2019.
o On several occasions (March 2019 and April 2019), mercury analysis did not meet the minimum
detection limit required by the STMP. The POTW reports that the Municipal Unit was notified of this
issue.
o Cyanide data was not reported on the DMR in several instances (February 2019 and April 2019). The
POTW notified the inspector that the cyanide data was missing and indicated that an amended DMR
would be submitted.
In 2019 Carolina Dairy had multiple limits violations for BOD, TSS, and pH. The SIU was in Significant Non -
Compliance (SNC) for BOD for both 6 month periods of the year. Carolina Dairy continued to have violations for
TSS, BOD, and pH in the first half of 2020. On June 9` 2020, the Town of Biscoe signed a Consent Order and
Compliance Schedule with Carolina Dairy to help them achieve compliance with Industrial User Permit (IUP)
limits. The POTW reports that Carolina Dairy has taken steps to reduce violations. These steps include providing
more training for the treatment operator and installing an inline pH meter for better process control of treatment
units. As per the Compliance Schedule, Carolina Dairy must prepare and submit a report to the Town of Biscoe
by August 712020, which outlines, "changes or additions to the current pretreatment process necessary to
achieve compliance with permit limitations, IUP, Part 1 Section F." Carolina Dairy must achieve compliance with
final IUP limits by December 1512020.
The POTW received an NOV on May 19th, 2020 for failure to adequately implement its Enforcement
Response Plan (ERP) during the 2019 PAR year. In the first six-month period of 2020, the POTW appears to
have taken steps to implement the ERP including initiating a Compliance Schedule with Carolina Dairy and
issuing NOVs and Penalty Assessments.
• Monitoring records submitted by the SIU to the POTW appeared complete including analytical data, flow,
and TTO certifications. Please include in the facility's pretreatment file the date that SIU records were
received to help establish if reporting deadlines were met.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

• An updated Industrial Waste Survey was submitted to the Municipal Unit on 6/15/20. The POTW is waiting
for the document to be approved by the Municipal Unit.
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:
OVERALL SUMMARY AND COMMENTS:
Comments
Requirements:
• Record flow data for future sampling events at Carolina Dairy as IUP 001 Part I, Section F.
• Maintain and retain all monitoring records for a minimum of three years as per NPDES Standard Conditions Part IV, Section D 12
and 15A NCAC 02H.908 (f). This includes pH, temperature, and flow measurements collected at SIUs.
• Ensure that the Division approved STMP is properly implemented by sampling at the correct frequencies, meeting minimum
detection limits, and reporting all effluent data on monthly DMRs as per NPDES Standard Conditions Part IV, Section D 3 and
15A NCAC 02H.0905.
• Update DMRs to include cyanide effluent data for 2/19 and 4/19.
Recommendations:
• Please include in the facility's pretreatment file the date that SIU records were received to help establish if reporting
deadlines were met.
NOD: [-]YES ®NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 5

NOV: [—]YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory Marginal x Unsatisfactory
PCI COMPLETED BY: Kristen Slodvsko DATE: 8/20/20
6SfU4, SIO SrO 8/20/2020
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 6