NC0024571_Pretreatment Inspection_20140221

ATAs
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
February 21, 2014
Steve West
Pretreatment Coordinator
City of Lumberton
P.O. Box 1388
Lumberton, NC 28359
SUBJECT: Pretreatment Compliance Inspection (PCI) Report
Lumberton WWTP
NPDES Permit No. NC0024571 -
Robeson County
Dear Mr. West,
Enclosed will find a copy of the Pretreatment Compliance Inspection report forthe
inspection that Trent Allen, Mark Brantley, and I performed on February 19, 2014 at the City of
Lumberton Wastewater Treatment Plant (WWTP), in which we met with you, Chris Conner
(Pretreatment Officer), and Tammy Smith (Laboratory Supervisor). An SIU file review, SIU site
visit, and POTW annual inspection of the SIU were performed on Elkay #1 (IUP#001). The
report indicates that the Lumberton POTW met the pretreatment requirements as outlined in 15A
NCAC 2H .0900 for Local Pretreatment Programs. If you have any questions or require
clarification, please do not hesitate to contact me at [phone].
Dale Lopez
Environmental Specialist
Enclosures: North Carolina Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
cc: Monti Hassan, PERCS-DWQ Pretreatment Unit
Chris Conner, Pretreatment Officer (sent via email)
--FRO Pr-etr-eatment_ale (Dale: op
225 Green Street— Suite 714 — Fayetteville,North Carolina 28301-5095
Phone: [phone] FAX: [phone] \ Customer Service 1-877-623-6748
Internet: www.ncwatereualitv.orq
An Equal Opportunity\Affirmative Acton Employer

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compiianne 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 N I 2 1 51 31 NC0024571 1 11 121 14/02/19 117
Type Inspector Fac Type
181 p I 191 S 1 201I
Remarks
211IIIIII1IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -------- ----------Reserved--------
671 3.0 1 69 701 31 711 I 721 N I 731 1 174 751 1 1 1 1 1 1 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)
Lumberton WWTP
700 Lafayette St Extension
Lumberton NC 28359
Entry Time/Date
10:00 AM 14/02/19
Permit Effective Date
11/04/01
Exit Time/Date
02:30 PM 14/02/19
Permit Expiration Date
14/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Jon W Locklear/ORC/910-671-3859/
Other Facility Data
'
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Wayne Horne,501 E 5th St Lumberton NC 28358//910-671-3806/9106713814 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
and checklists as necessary)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative
(See attachment summary) •
Nam and Signature(s) of Inspector Agency/Office/Phone and Fax Numbers' �9 D to
Dale Lopez �,, a FRO WQ//910-433-3300 Ext.712/ ®,;/ R i a ofit
i
Signature of-nagement Q/A eviewer Agency/Office/Phone and Fax Numbers Date
.1/2
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page #

NPDES
NC0024571
111 121
yr/mo/day
14/02/19
117
Inspection Type
181131
(cont .) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This Pretreatment Compliance Inspection report was for the inspection that Trent Allen, Mark Brantley, and I
performed on February 19, 2014 at the City, of Lumberton Wastewater Treatment Plant (WWTP)during
which we met with you, Chris Conner (Pretreatment Officer), and Tammy Smith (Laboratory Supervisor).
An SIU file review, SIU site visit, and POTW annual inspection of the SIU were performed at Elkay #1
(IUP#001). This report indicates that the Lumberton POTW met the pretreatment requirements as outlined
in 15A NCAC 2H .0900 for Local Pretreatment Programs.
Comments:
1. DMR and LTMP data were entered by staff into the Linko Pretreatment computer software, and the PT
Program SIU data and PAR data were entered into Captains Pretreatment Management software.
2. The pretreatment files were well organized.
Page # 2

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: City of Lumberton
2. Control Authority Representative(s): Chris Conner/Steve West
3. Title(s): Pretreatment Coordinator/Pretreatment Officer
4. Last Inspection Date: _07/16/2013 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
PCS CODING
Trans.Code
INl
Main Program Permit Number
1 N1CI0 10 12141517111
MM/DD/YY
J02119114]
Inspec.Type
Inspector Fac. Type
I PI j SI j 1 l
INSP) (FACC
7. Current Number Of Significant Industrial Users (SIUs)?
6
SIUS
8. Current Number Of Categorical Industrial Users (CIUs)? Trinity Manufacturing, Inc
1
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?
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 S1Us in SNC)
SNC for
SNC for
Not Pul
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 ONO
Limits:
Reporting:
lished:
0
0
0
None
❑ YES a NO
LTMP/STMP FILE REVIEW:
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 DWQ inspector, please veri
yoursel.fl
26. 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 DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

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)
08/26/2009
/1 Yes ❑ No
01/19/2010
/Z1 Yes ❑ No
09/01/2014
Industrial Waste Survey (IWS)
09/02/2010
1 Yes ❑ No
11/04/2010
►i1 Yes ❑ No
09/01/2015
Sewer Use Ordinance (SUO)
08/21/2012
/1 Yes ❑ No
09/17/2012
►1 Yes ❑ No
Enforcement Response Plan (ERP)
07/31/2009
❑ Yes 0 No
10/13/2009
1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
05/15/2013
Yes ❑ No
08/02/2013
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTIO
29. User Name
1 Elkay #1
2.
3.
30. IUP Number
001
31. Does File Contain Current Permit?
/i1 Yes ❑ No
mod. twice since
recently issued
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
03/31/2018
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
02/08/2012
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/i1 Yes ❑ No
09/26/2013
❑ Yes ❑ No
❑ Yes ❑ 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
07/08/2009
b. ■ Yes ■ No
a. ■Yes ■No
b. ■Yes ■No
a. Yes ■No
b. II 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
❑Yes❑NotN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►PYes •No
a. II Yes ■No
b.❑Yes ❑No❑N/A
a. IN Yes ■No
b.❑Yes ❑No❑N/A
07/12/2013
b.❑Yes ❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/Z1 Yes
❑
No
❑
Yes ❑ No
❑
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
11b. 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
12a. For categorical [Us with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
t2b. For categorical lUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
13a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
/1 Yes ❑ No
BOD 10/25/2013
❑ Yes ❑ No
❑ Yes ❑ No
13b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NolEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
14. 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 -
b.❑Yes ❑NooN/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
�6. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
0.
No
❑
Yes ❑ No
❑ Yes
❑ No
-7. 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
NOV 11/12/2013
❑Yes❑No❑N/A
❑Yes❑No❑N/A
.8. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
9. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A I
❑Yes❑No❑N/A I
❑Yes❑No❑N/A
NC DWQ Pretreatment Compliance Inspection (PCI) Form
Upda ed 7/25/07 Page 2

50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
a.oYes ❑No❑N/A
b.❑Yes ❑No❑N/A
a.❑Yes ❑No❑N/A
b.❑Yes ❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes ►1 No
.❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
1. The files were in good order. Please keep up the good work.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program,Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
I NI JNIC101012[415I7I1I I02119I14I JI I JSJ 121
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected:_Elkay Southern Corporation
2. Industry Address: 880 Caton Road, Lumberton, NC 28360
3. Type of Industry/Product: Industry for manufacture of stainless steel sinks
4. Industry Contact: Rodney Vernon Title: Environmental Lead
Phone:_J910) 737-3112 Fax: [phone]
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 Z YES ❑ NO
C. Pretreatment Tour ® YES ❑ NO
D. Sampling Review ® YES ❑ NO
E. Exit Interview ® YES ❑ NO
Industrial Inspection Comments:
Sheets of stainless steel plates were formed and annealed into sinks by means of applying heat and tons of pressure to stainless steel plates
pressed over metal die blocks. Potassium hydroxide was used to clean the metals.
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

OVERALL SUMMARY AND COMMENTS:
Comments:
1. DMR and LTMP data were entered into the Linko Pretreatment software. PT Program SIU data and PAR data were
entered into Captains Pretreatment Management software.
2. The pretreatment files were well organized.
Requirements: none
Recommendation: none
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory V r _final I UnSatisfactory
PCI COMPLETED BY: Dale Loez `-ATE: 02/21/2014
Reviewed by:
'CAD j
4 Date: 2j 5 - 0 Li
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4