NC0021873_Pretreatment Compliance Inspection Report - NOD-2020-PC-0435_20200826

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
August 26, 2020
Nadine Blackwell, Pretreatment Coordinator
P.O. Box 1279
Clemmons, NC 2012
SUBJECT: Pretreatment Compliance Inspection Report and Notice of Deficiency
NOD Tracking #NOD-2020-PC-0435
Town of Mayodan
NPDES# NCO021873
Rockingham County
Dear Ms. Blackwell:
On August 18, 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 (ERP).
Background
The Town operates one 2.5 MGD facility and has 3 significant industrial users (SIUs),
of which is categorical.
POTW Interview
The WWTP has not had any recent NPDES limits violations. Ms. Blackwell reported
difficulty with Strum Ruger (IUP#109) properly submitting reports and conducting required
sampling, leading to Significant Noncompliance.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on September 25, 2015 and
approved on December 7, 2015. The next HWA is due on September 30, 2020.
The Town's last Industrial Waste Survey (IWS) was submitted on September 28, 2018
and was approved on January 8, 2019. The next IWS is due October 1, 2023.
The last Long Term Monitoring Plan (LTMP) for was submitted on March 22, 2017 and
approved on June 14, 2017.
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
NOh �HCARO UHA
^^ •^ �ku^m I u�•i` r 336.776.9800

The Sewer Use Ordinance (SUO) was approved on December 14, 2012.
The ERP was approved on December 27, 2012.
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 Sans Technical (4108), Unifi (4105) and Strum, Ruger & Co
(#109) revealed that monitoring data was well organized and the slug control plans were in good
order.
However, it was noted that the POTW failed to independently measure flow when
conducting its routine sampling as required in the IUPs. The inspector discussed options for
measuring flow with the operators during the inspection.
The inspector also noted that, while Strum, Ruger & Co was in significant
noncompliance for the first semiannual period in 2019 for failure to adequately conduct required
monitoring and submit reports, the POTW did not take action on this violation until nearly 8
months after the end of that period in February, 2020. POTW should ensure that the time frames
specified in the ERP are followed when taking action on violations.
Conclusion
The issues noted above have collectively resulted in the issuance of this Notice of
Deficiency. Proper procedures were discussed with operators during the inspection. A formal
response to this letter is not required.
If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336)
776-9691 or our office at [phone].
Sincerely,
Docu Siiggned by:
L0� l t�Hl�tl
145B49E225C94EA...
Lon T. Snider., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures — PCI Report
CC: DWR Laserfiche Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION 1ComDlete Prior To PCI: Review ProLyram Info Database Sheets
1. Control Authority (POTW) Name: _Maw
2. Control Authority Representative(s): Nadine Blackwell
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 06/11/2018 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
I N I C 1 0 10 121 1181713
MM/DD/YY
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?
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 ?
1
16. Number of CIUs in SNC?
1
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 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 Pul
PAR)
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: 1
Ilished: I (to be published by next
None
❑ YES ® NO
LTMP/STMP FILE REVIEW:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

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!
Checked 6/2020 DMR
26. IfNO 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: Added:
8. 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)
9/25/2015
® Yes ❑ No
12/17/2015
® Yes ❑ No
9/30/2020
Industrial Waste Survey IWS
9/28/2018
® Yes ❑ No
1/8/2019
® Yes ❑ No
10/1/2023
Sewer Use Ordinance SUO
12/4/2012
® Yes ❑ No
12/14/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
12/20/2012
® Yes ❑ No
12/27/2012
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/22/2017
® Yes ❑ No
6/14/2017
® Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Sans Technical
2. Unifi
3. Strum, Ruger & Co
30. IUP Number
108
105
109
31. Does File Contain Current Permit?
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
6/30/2021
6/30/2021
6/30/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
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 ❑ NoI
® Yes ❑ NoI
® 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)
I b. [I es ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
Organic Management Plan (TOMP)?
I
I
Sample for TTO
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
FT��7'91
❑ Yes ®No
ElYes ® No
its Sampling as Required b IUP, includingflow?
1
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® 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❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/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❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reporting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoNN/A
a.❑Yes❑No®N/A
a.❑Yes❑NoNN/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.❑Yes❑NoON/A
c.❑Yes❑No®N/A
c.❑Yes❑NoNN/A
of SIU limit violations in the POTW's sampling of the SIU?
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❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoNN/A
a.❑Yes❑No®N/A
a.❑Yes❑NoNN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ®No
❑ Yes ®No
ElYes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
Strum, Ruger & Co was in SNC for reporting for the 1It semiannual period of 2019. However, it was noted that the violation letter was
not sent until 2/2020. POTW should ensure that the timeframes specified in the approved enforcement response plan are followed when
taking action on violations.
During review of POTW's sampling it was noted that flow was not recorded by the POTW personnel.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
l
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: _Please ensure that flow is measured during regular POTW sampling, and that violations are addressed in the time frames
specified in the annroved ERP.
Recommendations:
NOD: ® YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory Marginal XXX UnSatisfactory
Docu Signed by:
PCI COMPLETED BY: � � � Paul DiMatteo DATE:
F10=2F5BB34D4_.
8/18/2020
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4