NC0024112_Pretreatment Compliance Inspection_20210205

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
February 5, 2021
Misty Conder
Pretreatment Coordinator
City of Thomasville
P.O. Box 368
Thomasville, NC 27361
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Thomasville
NPDES# NC0024112
Davidson County
Dear Ms. Conder:
On January 21, 2021 a Pretreatment Compliance Inspection (PCI) was performed by Jim
Gonsiewski of the Winston-Salem Regional Office. Ms. Misty Conder was present for the
inspection. The purpose of this inspection was to determine the effectiveness of the Town's
pretreatment program, which includes reviewing the files, POTW plant performance, industry
monitoring data, and adherence to the enforcement response plan (ERP).
Background
This is a 6 MGD permitted facility. The City has five (5) Significant Industrial Users (SIUs), four
(4) of which are categorical. The publicly owned treatment works (POTW) has had exceedances
of BOD and TSS in 2019 and 2020 due to hydraulic issues caused by the weather. An exceedance
of Ammonia from an unknown source was also noted in 2020.
POTW Interview
There are no plant problems related to pretreatment issues and, other than BOD, Ammonia, and
TSS, there are no NPDES permit limit or monitoring violations recorded from December 2018
through December 2020. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on November 11, 2020. This HWA
renewal is currently under review.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

The last Industrial Waste Survey (IWS) was submitted on July 3, 2015. This IWS was approved
on September 11, 2015. The next IWS was due on December 31, 2020. A request for extension
was submitted.
The Sewer Use Ordinance (SUO) was approved on March 25, 2013.
The Enforcement Response Plan (ERP) was approved on February 14, 2020.
The Long Term Monitoring Plan (LTMP) was approved on March 5, 2019.
LTMP File Review
The Long Term Monitoring Plan (LTMP) is being conducted at the proper locations and
frequencies.
Industrial User Permit (IUP) File Review
Three (3) of the five (5) SIUs were in noncompliance in 2020.
A review of the file for Finch (#0018) revealed that the monitoring data was well organized and
compliant.
A review of the file for McIntyre Metals (#0031) revealed that the monitoring data was well
organized and compliant.
A review of the file for Custom Drum (#0029) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Finch (#0018) was in good order.
The slug control plan for McIntyre Metals (#0031) was not available. The POTW has requested a
revised plan.
The slug control plan for Custom Drum (#0029) was in good order.
Action Items
Due to the pandemic, none of the SIUs were physically inspected. However, Ms. Conder
maintained contact with the SIUs throughout the year.
The pretreatment program is considered satisfactory. Ms. Conder runs an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sino euSigneb by:
CLoti `C SMRCf
Lon $1..°gni er
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enclosure: PCI Report
cc: PERCS Unit — Mike Montebello (Electronic Copy)
WSRO Electronic Files
Laserfiche Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL DUALITY
BACKGROUND INFORMATION (Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Thomasville -Hamby Creek WWTP
2. Control Authority Representative(s): Misty Conder
3. Title(s): Lab Supervisor — Pretreatment Coordinator
4. Last Inspection Date: _ 12/19/18 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
1 NICI0 10 1 2 14 1 1 11 12 I 1 011 21 121
7. Current Number Of Significant Industrial Users (SIUs)?
5
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?
5
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 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)?
4
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 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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Put
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?
r YES ❑ NO
BOD, TSS - Flow related
Ammonia- unknown source
❑ YES // NO
Limits: None
Reporting: Custom Drum
lished: Will publish in 2/21
None
❑ YES // NO
McIntyre Metals made a verbal
request for relief of fines.
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23.
24.
25.
26.
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself!
If NO 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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page I

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)
11/01/2020
/4 Yes ❑ No
❑ Yes /1 No
In Review
Industrial Waste Survey (IWS)
07/03/2015
/1 Yes ❑ No
09/11/2015
/1 Yes ❑ No
12/31/2020 -
Requested
Extension
Sewer Use Ordinance (SUO)
01/31/2013
/1 Yes ❑ No
03/25/2013
a Yes ❑ No
Enforcement Response Plan (ERP)
02/11/2020
/1 Yes ❑ No
02/14/2020
►1Yes ❑ No
Long Term Monitoring Plan (LTMP)
01/25/2019
/1 Yes ❑ No
03/05/2019
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Finch
2. McIntyre Metals
3. Custom Drum
30. IUP Number
0018
0031
0029
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
01/31/22
06/30/22
01/31/21
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
---
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
❑ Yes /1 No
❑ Yes /1 No
❑ Yes ►1 No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. • Yes ■ No
b. ■Yes ■ No
a. ■ Yes • No
b. - Yes Yes ■ No
a. ►5 Yes ■ No
b. ■ Yes ■ No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
®Yes❑No❑N/A
❑Yes®No❑N/A
Requested
❑Yes❑NoON/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►iYes •No
b.❑Yes❑NotaN/A
a. ►SYes ■No
b.❑Yes❑No®N/A
a. Yes •No
b.❑Yes❑Not31N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
►1 Yes ❑ No
/1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
L Yes ❑ No
►1 Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes®No❑N/A
Problem with city
sewer. No flow.
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes®No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
Yes ❑ No
I Yes ❑ No
/1 Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes®No❑N/A
❑Yes®No❑N/A
®Yes❑No❑N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
a.❑Yes®No❑N/A
NO r s N DN/A
c.❑Yes❑No®N/A
a.❑Yes®No❑N/A
b.❑YestEINo❑N/A
c.❑Yes❑No®N/A
a.®Yes❑No❑N/A
b.❑Yes®No❑N/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ►1 No
❑ Yes // No
❑ Yes // No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
Fine issued
®Yes❑No❑N/A
Fine issued
❑Yes®No❑N/A
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?
b. Is SIU in Compliance with Order?
a.❑Yesi33No❑N/A
b.❑Yes❑NoEIN/A
a.❑Yes®No❑N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑NoE1N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes /1 No
❑ Yes // No
NC DWR Pretreatment Compliance Inspection (PC1) Form
Upda ed December 2016 Page 2

FILE REVIEW COMMENTS:
The files are in good order and well organized. Custom Drum has requested to be dropped from the program (the permit expired on
1/31/2021). Two new SIUs (both are centralized waste treatment facilities) may begin operation in 2021. Finch had one copper
exceedance in November 2020. McIntyre Metals had zinc exceedances in April and May 2020, a BOD, pH and zinc exceedance in
September 2020, and a TSS exceedance in May 2020. Custom Drum was in SNC for reporting in 2020. There was a problem with the
city sewer and the facility had no flow for several weeks. The SIUs were not physically inspected due to the pandemic. The
Thomasville City Hall is closed to visitors, so the collection of the required information for the IWS is taking longer than normal and
the POTW requested an extension for completion of the survey.
INDUSTRY INSPECTION ICIS CODING:
Main Program PermitNumber MM/DD/YY
J I I l 1 I I I I l 1 I I
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:
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal
PCI COMPLETED BY: Jim Gonsiewski
Unsatisfactory
DATE: 2/5/2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmo/day Inspection Type Inspector Fac Type
1 1ti 1 2 u 3 1 NC0024112 111 121 21/01/21 117 18I , I 1912 i 20[J
21111111
1
1
1 1 1 1 1 1 1 1 1 1 1 1
1 1
1 1 1
1 1
1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 r6
Inspection Work Days Facility Self -Monitoring
671 I 7013
Evaluation Rating
I 711
B1
I
QA
72 LJ 1 ry
I 73
Reserved
74 71
1
1
1 1
1 1 1 1
180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number).
Hamby Creek WWTP
110 Optimist Park Rd
Thomasville NC 27360
Entry Time/Date
10:05AM 21/01/21
Permit Effective Date
14/10/01
Exit Time/Date
11:45AM 21/01/21
Permit Expiration Date
19/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Roger G Bryant/ORC//
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Brandt,PO Box 368 Thomasville NC 273610368/Assistant City
Manager/336-475-4220/3364754283 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Records/Reports Compliance Schedules Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Jim J Gonsiewski
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Docusignedby: LDWR/Division of Water Quality/336-776-9704/
aoe-i 2/5/2021
E197B66f179D45F...
Signature of Management
Q A Reviewer Agency/Office/Phone and Fax Numbers Date
FDocuSigned by:
L-0, "T ,,,i'le.r. 2/5/2021
�— 145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/molday
31 NC0024112 111 121 21/01/21
17
Inspection Type
18101
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The files are in good order and well organized. Custom Drum has requested to be dropped from the
program (the permit expired on 1/31/2021). Two new SIUs (both are centralized waste treatment
facilities) may begin operation in 2021.
Finch had one copper exceedance in November 2020. McIntyre Metals had zinc exceedances in April
and May 2020, a BOD, pH and zinc exceedance in September 2020, and a TSS exceedance in May
2020. Custom Drum was in SNC for reporting in 2020. There was a problem with the city sewer and
the facility had no flow for several weeks.
The SlUs were not physically inspected due to the pandemic. The Thomasville City Hall is closed to
visitors, so the collection of the required information for the IWS is taking longer than normal and the
POTW requested an extension for completion of the survey.
Page# 2

Permit: NC0024112
Inspection Date: 01/21/2021
Owner - Facility: Hamby Creek VwVTP
Inspection Type: Pretreatment Compliance
Compliance Schedules
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Comment:
Yes No NA NE
❑ ❑ ❑ •
• ❑ ❑ ❑
Page# 3