NC0024571_Pretreatment Inspection_20170306

Water Resources
Environmental Quality
March 6, 2017
Beverly Allen
Pretreatment Coordinator
City of Lumberton
P.0 Box 1388
Lumberton NC 28359
SUBJECT: Pretreatment Compliance Inspection (PCI) Report
Lumberton WWTP
NPDES Permit No: NC0024571
Robeson County
Dear Mrs. Allen:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Enclosed please find a copy of the Pretreatment Compliance Inspection report from the inspection
conducted on 02/15/2017, at the City of Lumberton Wastewater Treatment Plant, in which I met with
Beverly Allen (Pretreatment Coordinator) andTammy Smith (Environmental Laboratory Supervisor). The
Inspection was conducted by Johnathan Watts, Environmental Specialist, of the Fayetteville Regional
Office. The report indicates that the Lumberton POTW met the pretreatment requirements as outlined
in 15A NCAC 2H .0900 for Local Pretreatment Programs.
Please refer to the enclosed inspection report for additional. observations and comments. If you or your
staff have any questions, please call me at 910-433-3322.
Sincerely,
Johnathan C. Watts
Environmental Specialist
Division of Water Resources
Water Quality Regional Operations Section
cc: PERCS Unit
AFRO PretreatmeIli 'Fifes(aJU1/)
-::4 ` Nothtnc
State of North Carolina I Environmental Quality
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5095
910-433-3300

United States Environmental Protection Agency
EPA Washington, D.C. 26460
Water Compliance 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 2[ I 3 I NC0024571 111 121 ' 17/02/15 117
Type •
18 I o I
I I I I I
Inspector
19 I
Fac Type
s I 20 I
21I.I I I I I I I I I I I i I 'I I l I I I I I I k i I I I -I
I I I
I I I I I l66
`
Inspection Work Days Facility Self -Monitoring
67I 170
Evaluation Rating B1 QA
I 711 I 72 � ti
1LJ
Reserved
1 1 1 1 1 1 180
l
------
751
731 I 174
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES oermit Number)
Lumberton WWTP
700 Lafayette St Extension
Lumberton NC 28359
Entry Time/Date
09:30AM 17/02/15
Permit Effective Date
-11/04/01
Exit Time/Date
01:OOPM 17/02/15 ,
-
1 Permit Expiration Date
14/07/31
Name(s) of Onsite Representative(s)lTitles(s)/Phone and Fax Number(s)
///
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) and Signature ) of Inspector(s)
Johnathan C Watts
Agency/Office/Phone and Fax Numbers Date
FRO WQ//910-433-3300/ - lt,- -ac 1 r I
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Trent Allen y Gl FRO WQ//910-433-3300/ - " 6, - 17
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

• s
NPDES yr/mo/day
NC0024571 111 121 17/02/15
17
Inspection Type
18 lol
(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 Johnathan Watts, of the
Fayetteville Regional Office, performed on Febrtaary 15, 2017 at the City of Lumberton Wastewater
Treatment Plant, which I met with Beverly Allen (Pretreatment Coordinator) and Tracy Smith
(Environmental Laboratory Supervisor). An SIU,file review and SIU site visit was performed at Elkay
(IUP#001). The report indicates that the Lumberton POTW met the pretreatment requirements as
outlined in 15A NCAC 2H .0900 for Local Pretreatment Programs.
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Lumberton
2. Control Authority Representative(s): Tracy Smith/Beverly Allen
3. Title(s): Environmental Laboratory Supervisor/Pretreatment Coordinator
4. Last Inspection Date: 06/11/2015 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
INI
Main Program Permit Number
MM/DD/YY
INICIO 10 12 1 41 5 1 7 11 1 1 02 1 15 12017 1
Inspec.Type
I P 1
Inspector Fac. Type
1 S 1 1 1 1.
(DTIA) (TYPI)
7. Current Number Of Significant Industrial Users (SIUs)?
(1NSP)
(FAUL
SIUS
7
8. Current Number Of Categorical Industrial Users (CIUs)?
1
CIUS
9. Number of S1Us 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
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, 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?
❑ YES NO
YES 41 NO
Limits: 1
Reporting: 0
lished:
❑ YES NO
LTMP/STMP FILE REVIEW:
22. Is LIMP/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 Division Inspector, please verify yourselfl
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES Z NO
If yes, which ones? Eliminated: Added:
NC DWR 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)
09/15/2014
'1 Yes ❑ No
09/18/2014
r Yes ❑ No
09/01/2019
Industrial Waste Survey (IWS)
08/15/2015
►ZI Yes ❑ No
11/20/2015
/5 Yes ❑ No
09/01/2020
Sewer Use Ordinance (SUO)
08/21/2012
►1 Yes ❑ No
09/17/2012
/I Yes ❑ No
Enforcement Response Plan (ERP)
07/31/2009
►1 Yes ❑ No
10/13/2009
I Yes ❑ No
Long Term Monitoring Plan (LTMP)
05/15/2013
►1 Yes ❑ No
08/02/2013
I Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Elkay
2.
3.
30. IUP Number
31. Does File Contain Current Permit?
0 Yes ❑ No
❑ 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?
/I Yes ❑ No
03/14/2016
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
@ Yes ❑ No
08/16/2016
❑ 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. JYes ■No
01/14/2016
b. •Yes ■No
a. ■Yes •No
b. ■Yes ■No
a. ■Yes ■No
b. ■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❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. 0Yes ■No
05/07/2013
b. ❑Yes❑No❑N/A
a. ■Yes ■No
b.❑Yes ❑No❑N/A
a. ■Yes ■No
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
41b. 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
42a. For categorical [Us with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoEIN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEIN/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?
►1 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
❑Yes❑No❑N/A
❑Yes❑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 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 ❑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❑NoEIN/A
❑Yes❑No❑N/A
❑Yes❑NopN/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❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
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.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes ❑No❑N/A
b.❑Yes ❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes
Al
No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
1. All files were available for direct access. Excellent records management.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector , Fac. Type
NI IN!CI0 10 12 14 15 17 11 1 102115 12017 1 1_1. ISj J 21
(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 manufacturing stainless steel sinks
4. Industry Contact: Rodney Vernon Title: Environmental Lead
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 ® 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:
Stainless steel sheet metal is formed into sinks through heating and pressing processes.
OVERALL SUMMARY AND COMMENTS:
Comments: 15. 1 SIU (Kayser Roth) in SNC for Chromium violation from January to June of 2016. Issue was corrected.
Requirements: None
Recommendations: None
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory . X Marginal UnSatisfactory
PCI COMPLETED BY: Johnathan Watts DATE: 03/06/2016
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3