NC0024571_Pretreatment Inspection_20021117

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
November 7, 2002
Ms. Karen Lewis
Laboratory Supervisor
City of Lumberton
P.O. Box 1388
Lumberton, NC 28359
SUBJECT: Pretreatment Compliance Inspection (PCI)
Lumberton WWTP
NPDES Permit No. NC0024571
Robeson County
Dear Ms. Lewis:
William G. Ross, Jr., Secretary
Alan Klimek, Director
Division of Water Quality
Enclosed please find a copy of the Pretreatment Compliance Inspection report for the
inspection conducted on October 22, 2002 at the City of Lumberton Wastewater Treatment Plant
(WWTP) in which I met with Karen Lewis (Laboratory Supervisor), Steve West (Laboratory
Pretreatment Officer), Chris Conner (Pretreatment Coordinator). The report indicates that the
Lumberton WWTP meets the pretreatment requirements as outlined in 15A NCAC 2H .0900 for
Local Pretreatment Programs. A file review was performed on the records of Pepsi Bottling
Ventures, Elkay 1, and Elkay 2. No Industrial Inspection was conducted during this Pretreatment
Compliance Inspection. The report is self-explanatory and contains observations and
recommendations. Where recommendations are cited, we ask that you provide a written description
of how each has or will be addressed. We ask that your response be forwarded to the Fayetteville
Regional Office by December 20, 2002.
We appreciate your cooperation and that of your staff. You are commended for your
continued success in maintaining your Pretreatment Program. If you or your staff have any
questions or require clarification, please do not hesitate to contact me at (910).486-1541.
Sincerely,
Dale Lope
Environmental Specia ist
/dl
Enclosures: Pretreatment Compliance Inspection Report
cc: Deborah Gore, DWQ Pretreatment Unit
Fayetteville Regional Office
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone]/FAX: [phone] Internet: www.ennstate.nc.us/ENR
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
FAYETTEVILLE REGIONAL OFFICE
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: Lumberton
2. Control Authority Representative: Karen Lewis/Steve West/Chris Conner
3. Title(s): Laboratory Supervisor / Laboratory PT Officer/ Pretreatment Coordinator
4. Last Inspection Date: 04/10/02 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: N/A Are Milestone Dates Being Met? Yes / No
PCS CODING
Trans.Code Program NPDES Number MM/DD/YY
JNI 1 NI CIO 10 12 14 15 17 11 J 10 /22 /02
(DTIA)
7. Current Number of Significant Industrial Users (SIUs)?
8. Current Number of Categorical Industrial Users (CIUs)?
Inspec.Type
J�
(TYPI)
Culp, Inc. IUP #008 was dropped as SIU
9. Number of SIUs Not Inspected by POTW in the Last Calendar Year?
10. Number of SIUs Not Sampled by POTW in the Last Calendar Year?
11. Enter the Higher Number of 9 or 10.
12. Number of SIUs With No IUP or With an Expired IUP?
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).
14. Number of SIUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods.
15. Number of SIUs in SNC for Limits Violations During Either of the Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods?
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? If Yes, 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?
Inspector
LSD
(INSP)
YES
Yes /
/ No
No
Fac.Type
i1J
(FACC)
9
1
0
0
0
0
0
0
0
0
SIUS
CIUS
NOIN
NOCM
PSNC
MSNC
SNPS
YES
INO
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 NO
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)
05/19/00
Industrial Waste Survey (IWS)
03/26/02
Sewer Use Ordinance (SUO)
09/17/96
Enforcement Response Plan (ERP)
05/31/95
Long Term Monitoring Plan (LTMP
•
11/22/00
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?
Yes
/ No
Yes /
Yes
No
/ No
25. Is the LTMP Data Maintained in a Table or Equivalent? . Ye / No Is the Table Adequate? Y s No
INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26. User Name.,
Pepsi Bottling Ventures
Elkay 1
Elkay 2
27. IUP Number
015
001
013
28. Does File Contain Current Permit?
Yes
Yes
Yes
12/31/00
12/31/00
12/31/00
12/31/04
12/31/04
12/31/04
29. Permit Expiration Date?
N/A
N/A
N/A
30. Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
Yes
Yes
Yes
31. Does the File Contain Permit Application Completed Within One Year
10/23/00
12/04/98
08/10/99
Prior to Permit Issue Date?
32. Does the File Contain an Inspection Completed Within Last Calendar Year?
Yes
Yes
Yes
10/16/01
12/14/01
12/14/01

33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
Yes
10/18/02
Yes
11/29/93
Yes
11/29/93
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
N/A
N/A
N/A
35. a. Does the File Contain Original Permit Review Letter from the.
Division?
b. All Issues Resolved?
a. Yes
b. Yes
a. Yes
b. Yes
a. Yes
b. Yes
36.
During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP?
Yes
Yes
Yes
37. Does File Contain POTW Sampling Chain -Of -Custody's?
(In Hydro Management's office, but not at the PCI.)
Yes
Yes
Yes
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required By IUP?
Yes
Yes
Yes
39. Does Sampling Indicate Flow or Production?
Yes
Yes
Yes
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Yes
Yes
Yes
41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self
Monitoring Violations? Copper violation of 0.061 lbs/day on
11/18/99.
b. Did Industry Resample Within 30 Days?
a. Yes
b. Yes
a. Yes (pH)
b. Yes
a.Yes (pH)
a. Yes
42. Was the SIU Promptly Notified of any Violations (Per ERP)?
Yes
Yes
Yes
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
No
No
No
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
N/A
Yes (NOV)
Yes (NOV)
45. Does the File Contain Penalty Assessment Notices?
N/A
N/A
N/A
46. Does the File Contain Proof of Penalty Collection?
N/A
N/A
N/A
0
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
N/A
N/A
N/A
48. Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
No
No •
No

FILE REVIEW COMMENTS
PCI SUMMARY AND COMMENTS
Lumberton WWTP Pretreatment Permit requirements appear to be met. Keep up the good work.
PCI Comments:
1. Pepsi Bottling Ventures ---A pennanent change is that the production line is moving to Raleigh near the middle of November
2002. Distribution will remain in operation, but there won't be production, only domestic. A drop request letter will be sent
to the PT Unit.
2. Four SIU site inspections have been performed as of the time of this PCI: Pepsi, Acme, Fun -Tees, and Kayser Roth.
3. Chris Conner performed the chemistry laboratory analysis for COD, BOD, and TSS. He also collected the metals and
transports them to TBL laboratory.
4. A new ISCO Glacier sample compositor was purchased. There was a total of four compositor, including the new one.
5. PreWin (computer program) was used to track the pretreatment data management of the PT program for Lumberton.
6. Way -Houser (formerly Willamette) will be an SIU by March 2003.
Requirements:
Recommendations:
1. Recommend updating the Spill Control Plan for Elkay 1. and Elkay 2.
2. All of the IUPs had Whole Effluent Toxicity (WET) testing requirements. Recommend dropping the WET by modifying the
IUPs.
NOD: YES 10
NOV: YES NO
QNCR: YES N�
POTW Rating:
Satisfactory, ✓ Marginal Unsatisfactory
PCI COMPLETED BY:
Dale Lopez, Environmental Specialist
Date: 11/07/02
Name and Signature of Reviewer Agency/Office/Telephone Date
Grady Dobson
NCDENR/Fayetteville/[phone] 11/07/02
//i `7 //ter

s.i
No Industrial Inspection was conducted during the PCI inspection
INDUSTRY INSPECTION CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
U I NI CIO to I I I I 1 1 / / I 1 l S 1 I21 1
. (DTIA) (TYPI) (INSP) (FACC)
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4.Industry Contact: Title:
Phone: Fax:
5.Does the POTW use The Division Model Inspection Fonn 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:

December 19, 2002
Mr. Dale Lopez
Environmental Specialist
Fayetteville Regional Office
225 Green Street -Suite 714
Fayetteville, NC 28301-5043
SUBJECT: Pretreatment Compliance Inspection (PCI) Response
Lumberton WWTP
NPDES Permit No. NC0024571
Robeson County
Dear Mr. Lopez:
A copy of the Pretreatment Compliance Inspection report for the inspection conducted on October 22, 2002
at the City of Lumberton Wastewater Treatment Plant (WWTP), dated November 7, 2002, was received on
November 12, 2002. Two recommendations were noted.
Recommendation #1: Updating the Spill Control Plans for Elkay #1 and Elkay #2. A SIU inspection for
both plants was conducted on 11/7/02 and a requirement was listed in the inspection report, under
Inspection Results, that an updated Spill Control Plan be completed and received by the City of Lumberton
Pretreatment Division by December 18, 2002. As of today's date, the Plans have not been received but are
in transit from both Elkays. When the City of Lumberton Pretreatment Division receives the updated
Plans, I will notify you by e-mail of the receipt.
Recommendation #2: All of the IUP's with Whole Effluent Toxicity (WET) testing requirements, drop the
WET by modifying the IUP's. The WET requirement in all IUP's have been removed. Some other minor
updates have been made as well in some of the IUP's. As soon as the fmal modifications are complete, the
City of Lumberton Pretreatment Division will forward to you a copy of the modified permits. The effective
date for all permits will be December 31, 2002.
We appreciate you patience as we continue to complete the above modifications. If you have any questions
or require clarification, please do not hesitate to contact me at [phone].
Sincerely,
Karen H. Lewis
Laboratory Supervisor
cc: Deborah Gore, DWQ Pretreatment Unit
Howard Revels, Environmental Services Director
Jim Walters, Environmental Services Deputy Director

LVAMILJ
Subject: toxicity test results (Cd7dFR)
Date: Thu, 19 Dec 2002 12:57:45 -0500
From: "Sandy Mort" <[e-mail]>
To: "dale.lopez" <[e-mail]>
ATU has completed the following toxicity test:
facility: Red Springs WWTP
test type: Cerio 7-day chronic FR
Permit limit: 90%
result: Chronic Value = 52.9% (FAIL on reproduction)
Sandy Mort, [e-mail]
Environmental. Biologist
NC DENR, Div. of Water Quality
Aquatic Toxicology Unit
4401 Reedy Creek Road
Raleigh, NC 27607
tel/vm: [phone] x242
fax: [phone]
1 of 1
12/19/2002 2:35 PM