NC0024571_Pretreatment Inspection_20020411

AccvA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
April 11, 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
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Enclosed please find a copy of the Pretreatment Compliance Inspection report for the inspection
conducted on April 10, 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
Kayser -Roth Corporation, Inc, Fun -Tees, Inc., and Lumberton Dying and Finishing. No Industrial Inspection
was conducted during this Pretreatment Compliance Inspection. The report is self-explanatory and contains
observations and recommendations. A form that might help the Pretreatment Coordinator keep up with the time
Constraints of the ERP for Limits & Late Reporting Violations was left with the Pretreatment Coordinator.
If you or your staff have any questions or require clarification. on part(s) of this report, please do not
hesitate to contact me at [phone].
Sincerely,
Dale Lopez
Environmental Specialist
/dl
Enclosures: Pretreatment Compliance Inspection Report
Long Term Monitoring Plan form
Cc: DWQ Pretreatment Unit
Fayetteville Regional Office
225 Green Street— Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.usJENR
An Equal Opportunity \ 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: 10/05/00 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
INI
Program NPDES Number
JNICIO 1012141517111
MM/DD/YY
04 / 10 /02
(DTIA)
Inspec.Type
IPI
(TYPI)
Inspector
(INSP)
EYES
Yes /
/ No
No
Fac.Type
1_1
(FACC)
7. Current Number of Significant Industrial Users (SIUs)?
10
SIUS
8. Current Number of Categorical Industrial Users (CIUs)?
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
0
NOCM
12. Number of SIUS With No IUP or With an Expired IUP? See Notes #A & #B
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).
1
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?
1
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, How Are
These Problems Being Addressed?
Fecal Coliforms permit limits were exceeded for two weekly violations and one monthly
violation for the month of November 2000. The reason was that hydrogen peroxide was used
instead of Chlorine for disinfection, and chlorine was put back online in December.
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

r'
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)
Acme (Zinc) one period (Jan. to Jun 2001)
SNC for Limits: 1
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?
25. Is the LTMP Data Maintained in a Table or Equivalent? es / No Is the Table Adequate?
INDUSTRIAL USER PERMIT (UP) FILE REVIEW
Yes
/ No
Yes /
Yes
Yes
No�
/ No
/ No
26. User Name
27. IUP Number
1. Kayser -Roth Corp., Inc.
2. Fun -Tees, Inc.
3. Lumber Dying & Finishing
004
007
28. Does File Contain Current Permit?
29. Permit Expiration Date?
30. Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
31. Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
32. Does the File Contain an Inspection Completed Within Last Calendar Year?
Yes / No
12/31/04
N/A
YES
/ No
11/30/98
Yes / No
I0/03/01
Yes,
12/31/04
YES
11/13/02
YES
005
Yes
12/31/04
N/A
YES
11/05/98
YES, 1/30/0I

33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. es / No
a. IYES
a. YES
b. Yes / No
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
Yes / No / IN/AI
NIA1
IN/A
35. a. Does the File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
a.Yes / No
a. [Yes]
a. Yes
b. 'Yes
b. Yes
b.Yes / No
36. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP'?
IYes / No
Yes
Yes
37. Does File Contain POTW Sampling Chain -Of -Custody's?
(In Hydro Management's office, but not at the PCI.)
Yes / No
Yes
Yes_
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required By IUP?
[Yes / No N/A
!Yes
IYes
39. Does Sampling Indicate Flow or Production?
/ No N/A
Yes
Yes
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Yes / No
[Yes
IYes
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 / No IN/Al
N/A
YES
b.Yes / No N/AI
N/AI
YES
42. Was the SIU Promptly Notified of any Violations (Per ERP)?
Yes / No N/A
N/A
N/A
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
Yes / NO
NO
NO
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
Yes /No N/A
N/A
IN/A
45. Does the File Contain Penalty Assessment Notices?
Yes / No NIAI
IN/Al
N/AI
46. Does the File Contain Proof of Penalty Collection?
Yes / No N/AI
N/AIN/AI
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
a.Yes / No /A
IN/A
Nj
b.Yes / No /A
N/A
E!a'
48. Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
Yes / INO
NO
NO

FILE REVIEW COMMENTS
Note #A: Willamette (a corrugated box manufacturer) is in the process of getting an IUP. POTW issued an A to C to Willamette.
There is a possibility that they will close soon, or sell to another company. (Update as of April 12, 2002, Way -Houser
purchased Willamette on March 19,2002. They will soon put in an effluent flume and will proceed with obtaining an IUP.)
Note #B: Pepsi Cola will be leaving, it will be dropped from compliance next year.
The IUPs for each of the SIUs require that LC50 aquatic toxicity testing be performed twice per year (but without permit limit
requirements). Since Lumberton WWTP is not having a problem with failures of its Whole Effluent Toxicity testing, and since
approximately 90% of the LC50 testing at the SIUs, effluents are failing the test (at the dilutions analyzed), the POTW might consider a
modification to the IUPs in which it would drop the aquatic toxicity requirements from the SIUs IUPs.
PCI SUMMARY AND COMMENTS
Lumberton WWTP Pretreatment Permit requirements appear to be met. Keep up the good work.
PCI Comments:
Requirements:
Recommendations:
Suggest that more Sampling equipment be available.
NOD: YES
NOV: YES
QNCR: YES
POTW Rating:
NO
NO
NO
Satisfactory
Marginal Unsatisfactory
PCI COMPLETED BY: Dale Lopez, Environmental Specialist
Date: April 10, 2002

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
INI J NI CIO I0 1 I I I 1 J / / LI_.l J S l J21 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 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:

amPeef
Long Tenn Monitorin6: Guidance
Appendix 4-R. Example LIMP Summary Data Form
POTW NAME _
NPDES/NONDISCHARGE PERMIT M -
• SAMPLE LOCATION =
Below Detection Limit Data (BDL) .should be marked as "<.and the detection limit", i.e. <0.002.
1
2
3
4
5
6
7
d
9
10
11
12
13
14
15
16
17
1 II
19
20
SAMPLE DATE
FLOW :
POLLUTANT
POLLUTANT =
POLLUTANT=
POLLUTANT =
POLLUTANT
POLLUTANT =
POLLUTANT =
POLLUTANT=
• TOTAL =
0VALUES=
AVERAGE
MAXIMUM =
MINIMUM =
BDL DATA USED FOR AVERAGES ARE ESTIMATED TO BE: (i.e. 0, 1/2 DETECTION LIMIT, THE DETECTION LIMIT).
Chapter: LTMP Guidance
Filename: LIMP data sum
Revision Date: Squashes I. 1993
Chapter 4
Appendix 4-8
Page 1