NC0024571_Pretreatment Inspection_20120531

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
May 31, 2012
Chris Conner
Pretreatment Coordinator
City of Lumberton
P.O. Box 1388
Lumberton, NC 28359
SUBJECT: Pretreatment Compliance Inspection (PCI)
Lumberton WWTP
NPDES Permit No. NC0024571
Robeson County
Dear.Mr. Conner,
Enclosed please find a copy of the Pretreatment Compliance Inspection report for the
inspection conducted on May 16, 2012 at the City of Lumberton Wastewater Treatment Plant
(WWTP) in which I met with you and Steve West (Pretreatment Officer). The report indicated that
after fulfilling the two requirements listed below (that are required to be implemented immediately),
the Lumberton WWTP would meet the pretreatment requirements as outlined in 15A NCAC 2H
.0900 for Local Pretreatment Programs. A file review and industry site visit was performed for
Buckeye (IUP #018).
Requirements:
1. Please require that Buckeye send a monthly record of the daily flows for each day of the month,
because the IUP indicated a "Daily Max" flow limit with a "Continuous" Monitoring Frequency.
2. Please require all of the SIUs that have IUPs that indicate a "Daily Max" flow limit with a
"Continuous" flow Monitoring Frequency to send the POTW a monthly record of the daily flows
for each day of the month. If there was a no flow condition on any day, then please indicate by
recording "No Flow" for that day.
If you have any questions or require clarification, please do not hesitate to contact me at
[phone].
225 Green Street -Suite 714 —Fayetteville, North Carolina 28301-5043
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.orq
An Equal Opportunity! Affirmative Action Employer
Nne
orth Carolina
Naturally

Mr. Conner
Page 2
May 31, 2012
Sincerely,
Dale Lopez
Environmental Specialist
Enclosures: North Carolina Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
cc: Monti Hassan, PERCS-DWQ Pretreatment Unit
Steve West, Pretreatment Officer (sent via email)
E-RO r tgg T ► ile 01a617 ope-2)

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water CC mpliAnne Irispec.tinn 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 INI 2 15 I ,• 31 . NC0024571 111 121 12/05/16 117
L_JRemarks
Type Inspector• ;.• = ; Fac Type
18I P I '• 19I S I 20I
21IIIIIIIIIIIIIIII IIII II1111II.IIIIIIIIIIIIIIIIIII66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ' ------Re6erved—=--------------
67I 2.0 .169 70 13 I 71 II 72I N I 731 I 174 75I I " I 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)
Lumberton WWTP
700 Lafayette St Extension
Lumberton NC 28359
Entry Time/Date
10:00 AM 12/05/16
Permit Effective Date
11/04/01
Exit Time/Date
02:00 PM 12/05/16
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)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) a ignature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Dale Lopez at& FRO WQ//910-433-3300 Ext.712/
n .
Date
/ V r
Signature of Management Q A Reviewer ' Agency/Office/Phone and Fax Numbers Date •
/1/44441-7 4/A1ha
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NC0024571 I11 12I 12/05/16 1 17 181
PI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed please find a copy of the Pretreatment Compliance Inspection report for the inspection conducted
on May 16, 2012 at the City of Lumberton Wastewater Treatment Plant (WWTP) in which I met with you and
Steve West (Pretreatment Officer). The report indicated that after fulfilling the two requirements listed
below (that are required to be implemented immediately), the Lumberton WWTP would meet the
pretreatment requirements as outlined in 15A NCAC 2H .0900 for Local Pretreatment Programs. A file
review and industry site visit was performed for Buckeye (IUP #018).
Requirements:
1. Please require that Buckeye send monthly records of the daily flows for each day of the month,
because the IUP indicated a "Daily Max" flow limit with a "Continuous" Monitoring Frequency.
2. Please require all of the SIUs that have IUPs that indicate a "Daily Max" flow limit with a "Continuous"
flow Monitoring Frequency to send the POTW monthly records of the daily flows for each day of the month.
If there was a no flow condition on any day, then please indicate by recording "No Flow" for that day.
Recommendation:
1. When the Industrial User Permits (IUPs) are being renewed in 2013, please speak with Monti Hassan
(PERCS) about the wording of the flow requirements for the IUP limits page.
If you have any questions or require clarification, please do not hesitate to contact me at [phone].
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: 09/15/2011 Inspection Type (Check One): ❑ PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? E YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ❑ NO
Order Type, Number, Parameters:
PCS CODING
Trans.Code Main Program Permit Number
NI
1 N 1 C 1 0 1 0 1214a 5 171 1[
Are Milestone Dates Being Met? ❑ V E:S ❑ NO
MM/DD/YY
Inspec.Type Inspector Fac. Type
1051161121. 1 PI J SJ J 11
DTIA) (TYPI) (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 InspectedByPOTW 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 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?
❑ Y E:S a NO
❑ YES 1 NO
Limits:
Reporting:
lished:
0
0
0
None
❑YES /1 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 verify
yourself
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: Mercury maybe 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, Progra»i
Element in their files; complete with supportine documents and cope of PERCS Approval Letter. and dates consistent with Pro Iran
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
08/25/2009
0 Yes ❑ No
01/19/2010
/i1 Yes ❑ No
09/01/2014
Industrial Waste Survey (IWS)
09/02/2010
/1 Yes ❑ No
11/04/2010
/1 Yes ❑ No
09/01/2015
Sewer Use Ordinance (SUO)
11/02/2006
1:/ Yes ❑ No
01/08/2007
/i1 Yes ❑ No
12/31/2012
Enforcement Response Plan (ERP)
07/31/2009
❑ Yes © No
10/13/2009
IZI Yes ❑ No
Long Term Monitoring Plan (LTMP)
05/12/2009
/1 Yes ❑ No
07/29/2009
►i4 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1 Buckeye Lumberton
2.
3.
30. IUP Number
31. Does File Contain Current Permit?
0 Yes ❑ No
Eff. 08/01/08
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
07/31/2013
33. Categorical Standard Applied (1.E. 40 CFR, Etc.) Or N/A
N/A •
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/I1 Yes ❑ No
12/27/2007
❑ Yes ❑ No.
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
►i4 Yes ❑ No
12/13/2011
❑ 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. 2Yes •No
11/2003
b. ■Yes ■No
a. ■Yes ■No
b. ■Yes ■No
a. EYes ■No
b. EYes ■No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑NOON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
a. iiYes ■No
a. ■Yes ■No
b.❑Yes❑No❑N/A
a. ❑Yes No
b.❑Yes❑No❑N/A
b. All Issues Resolved?
09/17/2008
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?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
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
Please see File Review Comment #1 and Requirement #1
41 b. During the Most Recent Semi -Annual Period, Did S1U submit all reports
on time?
®Yes❑No❑N/A
❑1'es❑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 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
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
►5 Yes ❑ No
❑ Yes ❑ No
❑ 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
❑Ycs❑No❑N/A
❑1'es❑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 reample 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❑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
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
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
❑Yes❑No❑N/A
❑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❑NoEiN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
NC DWQ Pretreatment Compliance Inspection (PCI) Form
Updated 7/25/07 Page 2

50. 'a: Des the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
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
❑ Yes i1 No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
I . The IUP flow indicated a "Daily Max" limit and Monitoring Frequency of "Continuous", but the SIU only reported the flows for
the days on which sampling occurred.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
1_N 1NIC101012141517111 1051161121 II l JS1 121
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Buckeye Lumberton
2. Industry Address: 1000 Noir Street Lumberton, NC 28354
3. Type of Industry/Product: Process and purify cotton fibers for food grade and pharmaceuticals grade cotton material.
4. Industry Contact: Deidra D. Holt Title: Quality Analyst/Environmental Coordinator
Phone: [phone] 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
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments:
® YES ❑ NO
® YES ❑ NO
® YES NO
®YES El NO
© YES ❑NO
This facility measured effluent flow by means of an in -line full pipe electromagnetic flowmeter, and the daily
flows were stored in the computer system. However, the daily flows for each day of the month were not reported
to the POTW, but only the flows for the days in which sampling occurred. (Please continue to perfoniu the annual
in-house flow meter calibration).
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

OVERALL SUMMARY AND COMMENTS:
Comments:
1. The IUP flow indicated a "Daily Max" limit and Monitoring Frequency of "Continuous", but the SIU only reported the
flows for the days on which sampling occurred.
2. The pretreatment files were well organized.
Requirements:
1. Please require that Buckeye send a monthly record of the daily flows for each day of the month, because the IUP
indicated a "Daily Max" flow limit with a "Continuous" Monitoring Frequency.
2. Please require all of the SIUs that have IUPs that indicate a "Daily Max" flow limit with a "Continuous" flow
Monitoring Frequency to send the POTW a monthly record of the daily flows for each day of the month. If there was a
no flow condition on any day, then please indicate by recording "No Flow" for that day.
Recommendations:
1. When the Industrial User Permits (IUPs) are renewed in 2013, please speak with Monti Hassan (PERCS) about the
wording of the flow requirements on the IUPs.
NOD: ❑ YES NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory V M. rginal UnSatisfactory
PCI COMPLETED BY: Dale Lo • ez WJ E: 05/31/2012
Reviewed by:
&L4 A96Ni!dD� Date:
411/1 a
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4