NC0028916_Pretreatment Inspection_20050209

NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
February 9, 2005
Roy Maness, Mayor
Town of Troy
444 North Main Street
Troy, North Carolina
SUBJECT: Pretreatment Compliance Inspection
Town of Troy WWTP
NPDES Permit. No. NC0028916
Montgomery County
William G. Ross Jr., Secretary
Alan W. Klimek, P.E.; Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
Dear Mayor Maness:
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the
inspection conducted on , January 26, 2005 in which I met with Gray Walls (Public Works
Director) and Linda Walls (Pretreatment Coordinator). The report indicates that Troy WWTP
continues to meet the pretreatment requirements as outlined in 15A NCAC 2H .09.04 (b) for
Modified Pretreatment- Programs. You are commended for your continued success in
maintaining your program.
The report is self-explanatory and contains observations, requirements and recommendations. If
you or your staff have any questions or require clarification, please do nothesitate to contact me
at [phone] or Deborah Gore at [phone], extension 593.
Sincerely,
Dale Lopez
Environmental Specialist
Enclosures: Pretreatment Compliance Inspection Report
Pretreatment Review of Long Term Monitoring Plan (June a 16, 2004 letter)
cc: Gray Walls, P.E., Town of Troy Public Works Director
Deborah Gore, PERCS - Pretreatment Unit
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] \ FAX: [phone] \ Internet: www:enr.state.nc.us/ENR/
An Equal opportunity./ Affirmative Action Employer - 50 Recycled 110 % Post Consumer Paper
Northarolina
aturalli

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance InspeCtton 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 LJ 2 II] 3 I NC0028916 111 121 05/01/26 117
Type Inspector Fac Type
18 U 1912] 20. U
III I.IIIIIIIIII166
Remarks
211 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---- —Reserved-------__--
67 I 2.0 169 70 el 71 U 72 LJ 731 1 174 751 1-1 I 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)
Troy WWTP
650 Glen Rd
Troy NC 27371
Entry Time/Date
11:00 AM 05/01/26,
:.
Permit Effective Date
04/08/01
Exit Time/Date.
02:00PM 05/01/26
Permit Expiration Date
09/06/30
Name(s) of Onsite Representative(s)lTitles(s)/Phone and Fax Number(s)
/I/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
E. Gray Walls,444 N Main St Troy NC 27371//910-572-7841/9105723663Contacted 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(s) and ature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Dat
Dale Lopezfa, FRO WQ//910-486-1541 Ext,712J pZ 5 65
Signature of Management Q A eviewer Agency/Office/Phone and Fax Numbers Date
.rl,649./7/.S
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES
NC0028916
111 121
yr/mo/day
05/01/26
Inspection Type
117 18 U
1
Section D: Summaryof Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
•
This facility has a conscientiously run program. Requirement:- Please perform the STMP as according to the June
16, 2004 from DWQ- Pretreatment Unit, implementing the STMP during the 3rd quarter of 2007 through the 3rd
quarter of 2008.

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: Gray Walls, P.E./Linda Walls
3. Title(s): Public Works Director/Pretreatment Coordinator
4. Last Inspection Date: June 8, 2004 Inspection Type (Circle One): pi 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
N1
Program NPDES Number MM/DD/YY
1 NI CIO 10 12 18 19 11 16 J O1 /26 /05
(DTIA)
Inspec.Type
IILI
(TYPI)
IN/AI
Inspector
(INSP)
`Yes
/No
Yes /
No
Fac.Type
(FACC)
7. Current Number of Significant Industrial Users (SIUs)?
2
SIUS
8. Current Number of Categorical Industrial Users (ClUs)?
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 SIUs 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

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
I10
PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headwork Analysis (HWA)
06/04/04
01/31/09
Industrial Waste Survey (IWS)
02/02/05
12/31/09
Sewer Use Ordinance (SUO)
02/02/05
01/31/05
Enforcement Response Plan
(ERP)
11/24/92
Long Term Monitoring Plan
(STMP)
06/16/04
22. Is the STMP Monitoring Being Conducted at Appropriate Locations and Frequencies?
23. Should any Pollutants of Concern be Eliminated From or Added to the STMP?
If Yes, which ones? Eliminated: Added:
24. Are Correct Detection Levels being used for all STMP Monitoring?
Yes
/ No
Yes /
Yes
fr o
/ No
25. Is the STMP Data Maintained in a Table or Equivalent? JYes / No Is the Table Adequate? es
/No

VIEW
26. User Name
1. Candor Hosiery
2. Capel
3.
27. IUP Number
0007
0002
28. Does File Contain Current Permit?
a.
Yes
/ No
IYesJNo
29.
Permit Expiration Date?
01/01/09
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?
Yes
/ No
O
o
09/03/03
08/18/03
32. Does the File Contain an Inspection Completed Within Last Calendar
Year?
[Yes
/ No
Elo
08/13/04
07/18/04
33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes
b. Yes
/ iill
/
Nol
a. Yes/No
b. Yes/f
.
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 IN/AI
35. a. Does the File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
EM
06/04/04
b.
Yes
o
a.
/ No
06/04/04
b.Yes
/ No N/A
36. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP?
'Yes
/ No
B
o
37. Does File Contain POTW Sampling Chain -Of -Custody's?
Yes
/ No
E
o
Located at the POTW
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
Yes
/ No N/A
E
o N/A
its Sampling as Required By IUP?
POTW does all of the sampling
39. Does Sampling Indicate Flow or Production?
Yes
/ No N/A
fres/No
40 During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
'Yes
/ No
E212o
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
a.Yes
/ No/
N/A
b.Yes
/ No/
b.Yes / No/ IN/A
1l/A
42. Was the SIU Promptly Notified of any Violations (Per ERP)?
IYesl / No N/A
Yes/No
N/A

43.
During the Most Recent Semi -Annual Period, Was the SIU in SNC?
Yes / Ilo
Yes/®
44.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
Yes /No/ II/AI
Yes/No IN/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 IN/AJ
47.
a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
a.Yes / No rN/A
b.Yes / No
Yes/NoIN/AI
N/A
48.
Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
Yes / No
Yes/ if
FILE REVIEW COMMENTS
PCI Comments: Conscientiously run program..
Requirements: Please perform the STMP as according to the June 16, 2004 letter (enclosed with this report), implementing the
STMP during the 3rd quarter of 2007 through the 3rd quarter of 2008.
Recommendation: None
Requirements from the 06/08/04 inspection report:
SUO --- Due to regulatory changes, the maximum fine in the SUO is now $25,000. Guidance for making this change will be available
on the Pretreatment web site within the next 4 weeks. Do not make this change without consulting the guidance. If you do not have
intemet access, call the Pretreatment Unit for hard copy. Submit the updated SUO to the Pretreatment Unit by January 31, 2005.
COMPLETE
The Town of Troy is a Modified Program and as such is only required to conduct a Short Term Monitoring Plan (STMP) for
development of the site specific HWA. Troy has voluntarily been conducting Long Term Monitoring. As discussed at the inspection,
Troy wishes to reduce the monitoring frequency to 1/ qtr for 4 consecutive quarters the year prior to the HWA. A review of the Plan
submitted in January will be sent under separate cover to address this change. Please note that EPA Method 1631 for mercury must be
used for effluent mercury sample analysis.
Note the due date for the Industrial Waste Survey — 9/30/2004.
Recommendation from the 06/08/04 inspection report:
COMPLETE
Pretreatment records starting before 1999 may be discarded at your discretion.

NOD: YES
NOV: YES
QNCR: YES
NO
NO
NO
POTW Rating: Satisfactory 1 Marginal Unsatisfactory
PCI COMPLETED BY: Dale Lopez, Env. Specialist Date:02/09/05
Name and Signature of Reviewer
�((}B���e�li1/1neda Henson
Agency/Office/Telephone Date
NCDENR/Fayetteville/[phone] a - 7 - D s

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
lv1 1111111 I11
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4. Industry Contact:
Phone: Fax:
LaJ 12(
(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:

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 16, 2004
GRAY WALLS
DIRECTOR OF PUBLIC WORKS
TOWN OF TROY
444 NORTH MAIN STREET
TROY NC 27371
Subject: Pretreatment Review of Long Term Monitoring Plan
Town of Troy
Montgomery County
NPDES Number: NC0028916
Dear Mr. Walls:
The Pretreatment Unit of the Division of Water Quality has reviewed the Long Term Monitoring Plan
(LTMP) submitted by the Town of Troy. This LTMP was received by the Division on January 6, 2004.
Review of the LTMP was delayed due to some anticipated changesto the Pretreatment Program that did
not occur.
As discussed at the Pretreatment Compliance Inspection conducted on June 8, the Town of Troy is a
Modified program and as such is required to perform Short Term Monitoring. Troy has voluntarily been
performing Long Term Monitoring and now wishes to decrease the monitoring frequency. The sampling
sites, pollutants of concern and detection requirements remain unchanged, except for mercury (see # 3
below). Attached are corrected pages to convert the LTMP to a STMP. The changes are as follows.
1. On page 2, the "First Year" and "Thereafter" columns are crossed off.
2. Also on page 2, under the "1 Year Before HWA" column the frequencies for influent and
effluent are quarterly on a workday. The frequency for SIUs is once for all POCs.
3. On page 3, the mercury method required for the effluent samples is specified.
The next HWA is due 1/31/2009, unless circumstances warrant an earlier revision. Therefore, the STMP
must be implemented during the 3`d quarter of 2007 through the 3rd quarter of 2008. This will allow at
least 4 months to complete the HWA.
Thank you for your continued cooperation with the Pretreatment Program. If you have any questions or
comments, please contact Deborah Gore at [phone] ext. 593 [email: [e-mail]].
Sincerely,
Alan W. Klimek
Enclosure: Corrected page 2 & 3 of STMP
dg/troySTMP.01
cc: Central Files
Deborah Gore, Pretreatment Unit, w/enclosure
Dale Lopez, FRO, w/enclosure
NC—DENR, DWQ, PRETREATMENT UNIT
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617
Wehsite: http://h2o.enr.state.nc.us/Pretreat/index.html
Telephone: [phone] Fax: [phone] ©'A
An Equal Opportunity Affirmative Action Employer NCDENR
50% recycled/10% post -consumer paper

Short
-bong Term Monitoring Plan
Activated Sludge / Aerobic Digester with Land Application of Biosolids
F. Sampling Frequency
Sampling Point
First Year
Thereafter
1 Year Before
HWA
1- Influent
Monthly on a
Workday and
per NPDES
requirement
'4 uarterly on a
Workday and
per NPDES
Requiremen
Mcrfthly on a
Workday and
per NPDES
requirement.
2- Effluent
Monthly on a
Workday and
per NPDES
requireme I
Quarterly o' a
Workday , d
per NP D ES
Req ' , - ment
Moptbly on a ��,c
Workday and ►
per NPDES
requirement
3- Activated
Sludge Basin
Once per :
months a . b)
One; per six
Mo % I (grab)
Once per six
months (grab)
4- Sludge to
Disposal
Per S dge
Pe uu ' and 503
regul "ons (1/yr)
' er Sludge
P - rmit and 503
gulations (1/yr)
Per Sludge
Permit and 503
regulations{44yr)-
Per SIU Permit
(Reco nded
for all .O.C.'s
once er year)
SIU's
0002 & 0007
Pe SIU Permit
1' ecommended
for all P.O.C.'s
once per year)
Per SIU Permit
(Recommended
for all P.O.C.'s
once per year)
l
G. Sampling Plan
P.O.C.
Pt. 1
Pt. 2
Pt. 3
Pt. 4
As
x
x
x
X
Cd
x
x
x
X
Cr
x
x
x
X
Cu
x
x
x
x
Pb
x
x
x
x
Hg
x
x
x
x
Mo
x
x
x
x
Ni
x
x
x
x
Se
x
x
x
x
Zn
x
x
x
x
Cn
x
x
x
x
Ag
x
x
x
x
NH3
x
x
Chloride
x
x
Flow
x
x
% solids
x
BOD
x
x
TSS
x
x
Tot. N
x
x
Tot. P
x
x
2

Short
4g Term Monitoring Plan
Activated Sludge / Aerobic Digester with Land Application of Biosolids
I. Detection Level and Sampling Method
P.O.C.
Detection Level
(ugn)
Sample Method
As
10
24 hr Composite
24 hr Composite
Cd
2
Cr
5
24 hr Composite
Cu
2
24 hr Composite
Pb :
10.
24 hr Composite
-* Hg
.2
24 hr Composite
Mo
5
24 hr Composite
Ni
10
24 hr Composite
Se
10
24 hr Composite
Zn
10
24 hr.Composite
BOD
2 mg/1
24 hr.Composite
TSS
2 mg/1
24 lir Composite
24 hr Composite
Tot. N
.5 mg/1
Tot. P
50
24 hr Composite
: Grab.
CN .
5
Ag
5
24 hr Composite
NH3
.1 mg/1
24 hr Composite
Chloride
: 1 mg/1
24 hr Composite
Sludge to Disposal samples and Septage samples will be grab.
Volatile P.O.C.'s shall be grab samples.
Sampling, preservation, and analytical method must be from 40 CFR 136.
Generally, Graphite Furnace Determinations are required to attain the desired detection
level for the metals.
y ` a "ram'
3