NC0028916_Pretreatment Compliance_20080806

Michael F. Easley, Governor
William G. Ross%Tr., Secretary
North Carolina Department of Environment and Natural Resources
• Coleen H. Sullins., Director
Division of Water Quality
August 6, 2008
Grey Walls
Town of Troy
444 North Main Street
Troy, North Carolina 27371
SUBJECT: Pretreatment Compliance Inspection
Town of Troy WWTP
NPDES Permit No. NC0028916
Montgomery County
Dear Mr. Walls:
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the
inspection that . was conducted on July 24, 2008 in which I met with you and Linda Walls
(Pretreatment Coordinator for the Town of Troy). The report indicates that Troy WWTP
continues to meet the pretreatment requirements as outlined in 15A NCAC 2H .0904 (b) for
Modified Pretreatment Programs. You are commended for your continued success in
maintaining your program.
The report is self-explanatory and contains observations. If you have any questions,
please contact me at [phone].
Environmental Specialist
Enclosures: Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
cc: PERCS - Pretreatment Unit
FRO Files
NorthCarolina
Naturally
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
FAYETTEVILLE REGIONAL OFFICE
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: Town of Troy
2. Control Authority Representative: Linda Walls
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 01/30/07 Inspection Type (Circle One): PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)?
6. Is POTW under an Order That Includes Pretreatment Conditions?
Order Type And Number: Are Milestone Dates Being Met?Yes / No /
PCS CODING
Trans.Code
JNJ
Program NPDES Number
NI CIO 10 1218191116
MM/DD/YY
07 / 24 / 08
(DTIA)
Inspec.Type
JPJ
(TYPI)
N/A4
Inspector
LS1
(INSP)
IYes
/ No
Yes /
Fac.Type
I1J
(FACCI
7. Current Number of Significant Industrial Users (SIUs)?
2
SIUS
8. Current Number of Categorical Industrial Users (CIUs)?
0
CIUS
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. Enter the Higher Number of 9 or 10.
0
NOIN
12. Number of SIUs With No IUP or With an Expired IUP?
0
NOCM
13. Number of SIUs In SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of SIUs in SNC).
0
PSNC
14. Number of SlUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods.
0
MSNC
15. Number of SIUs in SNC for Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
SNPS
16. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods?
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?
YES
NO
YES
NO

. 1
19. Which Industries have been in SNC during either of the Last 2 Semi -
Annual Periods? Have any Industries in SNC (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 Limits: 0
SNC for Reporting: 0
Not Published:
0
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?
None
YES
NO
PRETREATMENT PROGRAM. ELEMENTS REVIEW - Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable
06/07/04
01/31/09
Headwork Analysis (HWA)
Industrial Waste Survey (IWS)
02/02/05
12/31/09
Sewer Use Ordinance (SUO)
02/02/05
06/01/07
Revised SUO submitted to Information
Processing Unit on 02/14/08
Enforcement Response Plan
(ERP).
11/24/92
Long Term Monitoring Plan
06/16/04
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies?
23. Should any Pollutants of Concern be Eliminated From or Added to the LTMP?
If Yes, which ones? Eliminated: Added:
24. Are Correct Detection Levels being used for all LTMP Monitoring?
IYes
/ No
Yes /
Yes
No
/ No
25. Is the LTMP Data Maintained in a Table or Equivalent? . IYes / No Is the Table Adequate? fres / No

INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26. User Name
Elite Foods
2. Capel
3.
27. IUP Number
0009
0002
28. Does File Contain Current Permit?
h'es/No
Yes/No
01/01/04
29. Permit Expiration Date?
01/01/09,
SIU
Feb.
are
the
complete
This
closed during
2008, and
waiting for
buyout to
01/01/09
30. Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
N/A
N/A
31. Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
N
o
N
o
32. Does the File Contain an Inspection Completed Within Last Calendar
Year?
fres/No
[Yes/No
12/13/07
12/10/07
33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes/No
b. Yes/
1]
a. Yes/No
b. Yes/No
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
Yes/No,
N/A
Yes/No
N/Al
35. a. Does the File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
E
b.
YesNM
Illo
.
36. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP?
EM
Ello
37. Does File Contain POTW Sampling Chain -Of -Custody's?
N
NM
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
Yes/No
N/A
Ello
N/A
its Sampling as Required By IUP?
The POTW does all of the
SIU
closed
sampling on an unannounced monthly sampling schedule. All
during
Feb. 2008
samples are sent to Meritech.
See
PCI
Requirement
(below)
39. Does Sampling Indicate Flow or Production?
f Yes/No
[Yes/No
40 During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Ello
N o
No Non -
Compliance
41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations
b. Did Industry Resample Within 30 Days?
a.Yes / No/ IN/AI
N/
b. es No/ N/A
Yesl

42. Was the SIU Promptly Notified of any Violations (Per ERP)?
Yes/No N/A
rl'es/No N/A
43. During the Most Recent Semi -Annual Peiiod, Was the SIU in SNC?
Yes/�l
Yes/Fl
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
Yes/No N/A
gm o N/A
45. Does the File Contain Penalty Assessment Notices?
Yes/No N/A
Yes/No N/A
46. Does the File Contain Proof of Penalty Collection?
Yes/No N/A
Yes/No N/A
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
Yes/No N/A
Yes/No INUA
48. Did the PO.TW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
Yes/f1
Yes/F1
FILE REVIEW COMMENTS
PCI Comments:
1) A Conscientiously run program.
2) A revised SUO was submitted to the Information Processing Unit (1617 Mail Service Center) on 02/14/08, and recently
resent to the Fayetteville Regional Office on 07/31/08. FRO forwarded the SUO to Monti Hassan (PERCS Unit).
Presently, the.SUO is being reviewed by the PERCS Unit.
Recommendation: .
PCI Requirement:
Please send a Drop Request letter to Monti Hassan (PERCS Unit) for Elite Foods. The letter should include three items. (#1) a
short explanation as to the reason that the flow has ceased at Elite Foods. In this case, the reason might be that there was no process
flow due to the industry going out of business. (#2) As according to the Comp. Guide, Chapter 3, Appendix 3-A, "The Division
needs a copy of the letter from the POTW to the user stating that their permit is revoked." (#3) Please also include a copy of an
SIU inspection form that indicates confirmation and documentation of the no flow conditions at Elite Foods.
NOD: YES
NOV: YES
QNCR: YES
NO
NO
NO
POTW Rating: Satisfactory ✓ Marginal Unsatisfactory• .
\'l
PCI COMPLETED BY: Dale Lopez, Environmental Specialist `ti �� af 08/06/08
Name and Signature of Reviewer
1.
Agency/Office/Telephone Date
Belinda Henson NCDENR/Fayetteville/ [phone]

INDUSTRY INSPECTION CODING:
No Industrial Inspection was conducted during the PCI Inspection
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
11.1 1111111 111
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4. Industry Contact:
Phone:
Fax:
_/ / j I I S j21
(DTIA) (TYPI) (INSP) (FACC)
5.Does the POTW use The Division Model Inspection Form or Equivalent?
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
B Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments:

United States Environmental Protection Agency
EPA 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 yr/mo/day Inspection
1 I NI 2 15I ' 31 NC0028916 111 121 08/07/24 117
Type Inspector Fac Type
181 pl 19I RI 20I II
1 1 I L I 1 1 1 1 1 1 1 1 1 1 166
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 1 I I_ 11 1 1 1 1 1 1 1 111 11 1 1
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 3.0 169 70 13 IL_J 711 I 721 NI 731 I 174 751 1 I I l 1 I 1 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Troy WWTP
650 Glen Rd
Troy NC 27371
Entry Time/Date
11:00 AM 08/07/24
Permit Effective Date
04/08/01
Exit Time/Date
01:30 PM 08/07/24
Permit Expiration Date
09/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joseph Edward Shields/ORC/910-572-3661/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
E. Gray Walls,444 N Main St Troy NC 27371//910-572-7841/9105723663
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( Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dale Lopez's\ / FRO WQ//910-433-3300 Ext.712/ J S' 41
Signature of Management Q A Revie er Agency/Office/Phone and Fax Numbers Date-i2oLeho i qittgJrt., 7/ 74 r
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

31
NPDES
NC0028916
111 121
yr/mo/day
08/07/24
Inspection Type
1 17 181P1
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
A conscientiously run PT program. A revised SUO was submitted to the Information Processing Unit (1617
Mail Service Center) on 02/14/08, and recently it was resent to the FRO on 07/31/08. FRO forwarded the
SUO to PERCS Unit and is presently being reviewed. Please send a Drop Request letter to the PERCS
Unit for Elite Foods.
Page # 2