NC0044776_Audit Report_20210621

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheets
1. Control Authority (POTW) Name: Town of Hamilton
2. Control Authority Representative: Kerry Spivey
3. Title: Wastewater Treatment Plant ORC
4. Address of POTW:
Mailing P.O. Box 249
City Hamilton
Zip Code 27840
Phone Number 252-798-2001 Fax Number 252-798-1660 E-Mail kerrys(i/suddenlinkmail.com
5. Audit Date 6/8/2021
6. Last Inspection Date: 4/11/2019 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. There was a weekly average exceeded for TSS in October 2020.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICIOIOI4 I4 17 17 I6 I
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
MM/DD/YY
16 IR I21I
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC with Pretreatment Schedule?
1
0
0
0
0
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
1
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and 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)
4/19/18
a Yes ❑ No
10/26/2018
i1 Yes ❑ No
4/1/23
Industrial Waste Survey (IWS)
5/17/17
a1 Yes ❑ No
5/18/17
I1 Yes ❑ No
3/1/22
Sewer Use Ordinance (SUO)
11/7/12
/1 Yes ❑ No
11/19/12
/1 Yes ❑ No
Enforcement Response Plan (ERP)
6/5/2020
/1 Yes ❑ No
9/3/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/24/20
0 Yes ❑ No
5/27/20
/1 Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 11/1/12
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
29. Please Rate the Followine: S=Satisfacto
M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
a S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1 S ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Town of Hamilton has 1 industry that samples quarterly. All paperwork is kept in hard copies.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Annual fee to Industry, plus enforcement costs if needed
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? Would make files available
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Would mark confidential on file folder and keep in file
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No If changed public would be notified
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Kerry is on the Town Board and any new Business
comes through the Town Board
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Town will meet onsite to discuss and tour facility
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
EYes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) N/A
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW' s copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter % No specific percentage. Currently only 1 industry in Town
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
After sampling the facility the Town would contact PERCS unit for guidance
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Hamilton would contact PERCS for guidance. SIU currently samples quarterly
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Reviews lab results and compares data to SIU's permit
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Penco is required to have a slug/spill plan
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
A contact list and a written plan to shut off pump station is in the Spill Control plan
56. How does the POTW decide where the sample point for an SIU should be located?
Sample prior to discharge
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Kerry trains personnel on sampling
58. Who performs sample analysis for the POTW for Metals Environment 1
Conventional Parameters Environment 1
Organics Environment 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Chain of Custody is filled out with samples sent to Environment 1.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES El NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ❑ YES El NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES El NO Division Inspector, verify yourself!
60e. If NO to any above, list violations STMP is only sampled before permit renewal
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone ( ) --
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow
❑More LTMP data available
Explain.
❑Resolve over allocation 05 year expiration
❑NPDES limits change
❑Other
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTIO
66. User Name
1. Penco Products
2.
3.
67. IUP Number
001 J
68. Does File Contain Current Permit?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
2/3/2023
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain 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 ■ No
a. •Yes ■ No
b. •Yes ■ No
Certification, Does File Contain a Toxic
(TOMP)?
El Yes ❑No❑N/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No®N/A
a. •Yes •No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80a. 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
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reportin Non -Compliance from SIU Sampling?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes®No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 1 No
❑ Yes ❑ No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
DYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑N°ON/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative
Information For You?
Have Difficulty in Obtaining Any Requested
❑ Yes A No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
Town of Hamilton is required to sample Penco quarterly. The quarterly sample taken by the Town of Hamilton on 3-25-2020 showed zinc
was out of limits with the sample result of 3.940 mg/1. The Town of Hamilton did not resample within 30 days as required. The Town was
reminded that when any parameter exceeds the permitted limits a resample needs to be taken within 30 days. The Town's next quarterly
sample was taken on June 17, 2020 and all samples were complaint with Penco's permit.
A copy of the approval letter for the Enforcement Response Plan is attached to this inspection and needs to be maintained in the file.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIn In 14 14 17 17 16 1 16 IR 1211
1. Industry Inspected: Penco Products
2. Industry Address: 1301 Penco Drive, Hamilton NC 27840
3. Type of Industry/Product: Metal Locker fabrication
4. Industry Contact: Wesley Green Title: Water Treatment Operator Phone: [phone] ext. 250 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:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements:
Recommendations: The Town needs to have a better filing system for future PCI's or Audits.
NOD: ❑ Yes ❑ No
NOV: ❑ Yes ❑ No
QNCR: ❑ Yes ❑ No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: /8,664:e- Sli: DATE: 6/21/2021
PERCS, and WaRO Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6