NC0069311_NOV-2021-PC-0562_20211115

DocuSign Envelope ID: 81 B06A42-8696-4E42-8E13-6B9DEC2F49C1
ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7017 2680 0000 2237 4748
Return Receipt Requested
November 15, 2021
Chris Doherty
Director of Public Utilities
Franklin County
1630 US Highway 1
Youngsville, NC 27596
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Case No. NOV-2021-PC-0562
Pretreatment Compliance Inspection
Franklin County
Franklin County WWTP - NPDES Permit No. NC0069311
Franklin County
Dear Mr. Doherty:
On August 25, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
compliance inspection of Franklin County's pretreatment program. The assistance given by
Mr. Paul Langfield, the WWTP Superintendent, and Martin Kurian, the Pretreatment
Coordinator, was greatly appreciated. The inspection report is attached. Findings during
the inspection were as follows:
1. The County has two Significant Industrial Users (SIUs), one is also a Categorical
Industrial User (CIUs). It was noted that neither SIU was in SNC for the most recent
two semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted.
Franklin County was found to have violated Section D, 4 of its NPDES permit
for failure to submit update of Headworks Analysis before the due date, which
was December 1, 2020. Short Term Monitoring plan, Enforcement Response Plan,
and Sewer Use Ordinance were updated and approved by the Division in 2020.
3. Short Term Monitoring Plan (STMP) data were reviewed during the inspection. It
was noted that all locations were sampled with required frequencies and all samples
analyzed with required detection levels since the last inspection.
NOR�D_E
�aearbnenl al Environmental 9uallly
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 81 B06A42-8696-4E42-8E13-6B9DEC2F49C1
4. The pretreatment inspection file review included Novozymes (Permit No. 0112) and
Southern Lithoplate (Permit No. 0103). During the most recent semi-annual period:
• The POTW was unable to sample Southern Lithoplate because the SIU has
not discharged since the end of February 2021. Southern Lithoplate did not
have any limit violations, but failed to submit certification for TTO. The
POTW failed identify this reporting violation;
• Southern Lithoplate does not have a slug/spill control plan, while its
IUP requires the SIU to develop and implement a slug/spill control plan.
• Novozymes had one ammonia violation in March 2021 and one total nitrogen
violation in April 2021. The POTW issued two Notices of Violation to
Novozymes.
• Franklin County was found to have violated Section D, 7 of its NPDES
permit for failure to inspect the SIUs in 2020.
5. It was noted during the inspection that the POTW representatives had
difficulty to locate files needed for review (Review letters from the Division
for Headworks Analysis, Industrial Waste Survey, Industrial User Permits
(IUPs), etc.). Improvement is needed in record keeping and organization.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of
North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars
($25,000.00) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S. 43-215.1.
Please respond in writing to RRO within 30 days of receipt of this letter regarding
Items 2 and 4. If you have any questions or comments, please call Cheng Zhang at (919)
791-4200 (or email: [e-mail]).
Sincerely,
,-DocuSigned by:
Sit �U,
BCDA9D825D4A46D...
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Siler City Pretreatment Audit Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO
Paul Langfield, Franklin County (Electronic copy only)
1:11
NORTH CAgD'_INA
Oopanmenl ¢I Enrimnmenul Puality
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 6B177071-ODBD-45C3-9D56-DDE108FEFA6F
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Franklin County
2. Control Authority Representative(s): Martin Kurian
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 9/19/2019 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
ICIS CODING
Main Program Permit Number
J NICIO 10 16191311111 1081251211
MM/DD/YY
7. Current Number Of Significant Industrial Users (SIUs)?
2
8. Number of SIUs With No IUP, or With an Expired IUP?
0
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. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
1
16. Number of CIUs in SNC?
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 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 /1 NO
❑ YES A NO
Limits: None
Reporting: None
lished: None
None
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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 ® N/A
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division 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: Added:
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 6B177071-0DBD-45C3-9D56-DDE108FEFA6F
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 Approva 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)
11/30/2015
❑ Yes ►1 No
03/18/2016
❑ Yes /1 No
12/1/2020
Industrial Waste Survey (IWS)
3/31/2017
❑ Yes ►1 No
7/11/2017
❑ Yes /1 No
3/5/2022
Sewer Use Ordinance (SUO)
11/22/2019
a Yes ❑ No
4/15/2020
r Yes ❑ No
Enforcement Response Plan (ERP)
1/31/2020
a Yes ❑ No
2/13/2020
/1 Yes ❑ No
Short Term Monitoring Plan (STMP)
2/17/2020
a Yes ❑ No
4/29/2020
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Novozymes 2. Southern Lithoplate
3.
30. IUP Number
0112
0103
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
9/22/2023
12/31/2024
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433.1, 7
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
@ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
❑ Yes /1 No
❑ Yes r No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. AYes ■No
b. •Yes ■ No
a. •Yes LNo
b. A Yes ■ 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
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. •Yes No
b.❑Yes❑No❑N/A
a. •Yes LNo
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 r No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
/1 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
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑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❑NoON/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No ON/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
® Yes ❑No❑N/A
❑Yes❑No ON/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoON/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❑NoEIN/A
b.❑Yes❑NoEIN/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes /1 No
0 ❑ Yes L No
0
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 ON/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑NoON/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❑NoEIN/A
a.❑Yes❑NoEIN/A
b.❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
/1 Yes ❑ No
r Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 6B177071-0DBD-45C3-9D56-DDE108FEFA6F
FILE REVIEW COMMENTS:
28 — The POTW failed to submit Headworks Analysis before the due date (December 1, 2021).
35 - The POTW did not inspect SIUs in 2020.
36 — Southern Lithoplate does not have a slug/spill control plan, while its IUP requires the SIU to develop and implement a slug/spill
control plan.
38 - Original Permit Review Letters from the Division were not available for review.
39 — The POTW was unable to sample Southern Lithoplate because the SIU stopped discharging.
41b — Southern Lithoplate did not submit TTO certification for the semi-annual period. The POTW did not identify this reporting
violation.
43a — Novozymes had one total nitrogen violation (in April 2021) and one ammonia violation (in March 2021). had one copper and one
zinc violation from POTW sampling, and one lead violation from SIU sampling.
44b — SIU resampled within 30days as required by the POTW.
47 - The POTW issued two NOVs for the above violations.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 1
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 ❑ 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:
OVERALL SUMMARY AND COMMENTS:
Comments: Due to personnel turnover, pretreatment files were not organized, the coordinator had difficulty to locate some files. The
POTW failed submit HWA before the due date and did not inspect SIUs in 2020.
Requirements: Submit HWA analysis as soon as possible.
Recommendations: The WWTP superintendent/ORC should be more involved in pretreatment, the coordinator is struggling to maintain
the pretreatment program.
NOD: ❑ YES ® NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 25, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3