NC0026689_Pretreatment Inspection Report_20211209

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Troy Branch
Pretreatment Coordinator
Town of Denton
P.O. Box 306
Denton, North Carolina 27239
NORTH CAROLINA
Environmental Quality
December 9, 2021
SUBJECT: Pretreatment Compliance Inspection (PCI)
Town of Denton
NPDES# NC0026689
Davidson County
Dear Mr. Branch:
On November 23, 2021 a Pretreatment Compliance Inspection (PCI) was performed by Jim
Gonsiewski of the Winston-Salem Regional Office. Troy Branch was present for the inspection.
The purpose of this inspection was to determine the effectiveness of the Town's pretreatment
program, which includes reviewing the files, POTW plant performance, industry monitoring data,
and adherence to the enforcement response plan (ERP).
Background
This is a 0.8 MGD permitted facility. The Town has one (I) Significant Industrial User (SIU)
which is not categorical. The publicly owned treatment works (POTW) has had five exceedances
of dichlorobromomethane in April 2021, May 2021, July 2021, August 2021, and September 2021.
This has been a recurring problem. The Town is actively working to eliminate this constituent. A
major renovation of the chlorine contact chamber is scheduled to begin in December 2021 and
should be completed in 2022.
POTW Interview
There are no plant problems related to pretreatment issues and, other than dichlorobromomethane,
there are no NPDES permit limit or monitoring violations recorded from November 2020 through
November 2021. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on August 24, 2021. The HWA is
currently under review.
DE
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North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

The last Industrial Waste Survey (IWS) was submitted on May 11, 2020. The IWS was approved
on August 5, 2020. The next IWS is due on March 31, 2025.
The Sewer Use Ordinance (SUO) was approved on January 18, 2013.
The Enforcement Response Plan (ERP) was approved on March 17, 2020.
The Short Term Monitoring Plan (STMP) was approved on October 24, 2017.
STMP File Review
The STMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
The SIU was in compliance in 2020.
A review of the file for Century Hosiery (#0001) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Century Hosiery (#0001) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Branch runs an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
r---oocuSIgnod by:
1. oN -T. SMIECr
LOris l .E'4niaer
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enclosure: PCI Report
cc: PERCS Unit — Michael Montebello (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
av+n vni Emoonmex.,i aa.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

0NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVALITY
BACKGROUND INFORMATION 'Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Denton
2. Control Authority Representative(s): Troy Branch
3. Title(s): Pretreatment Coordinator/WWTP ORC
4. Last Inspection Date: 12/17/21 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 MM/DD/YY
NICIO 1 0 1 2 1 6 16 1 8 19 1
J 11 123 I 21 l
7. Current Number Of Significant Industrial Users (SIUs)?
1
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)?
0
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?
The POTW has likely identified the source of the exceedance and is making
upgrades to correct the problem.
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
Dichlorobromomethane•
exceedances in April, May, July,
August, and September.
❑ YES /1 NO
Limits: N/A
Reporting: N/A
lished: N/A
None
❑ YES // 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 Division Inspector, please verify.
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: Bis(2-Ethylhexyl) Phthalate
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 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 1
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
08/24/2021
►1 Yes ❑ No
❑ Yes ❑ No
In Review
Industrial Waste Survey (IWS)
05/11/2020
/1 Yes ❑ No
08/05/2020
0 Yes ❑ No
03/21/2025
Sewer Use Ordinance (SUO)
01/04/2013
Yes ❑ No
01/18/2013
/' Yes ❑ No
Enforcement Response Plan (ERP)
12/31/2019
O Yes ❑ No
03/17/2020
Yes ❑ No
Short Term Monitoring Plan (STMP)
08/09/2017
/1 Yes ❑ No
10/24/2017
/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. Century Hosiery, Inc.
2.
3.
30. IUP Number
0001
31. Does File Contain Current Permit?
/1 Yes
❑ No
❑ Yes ❑ No
❑ Yes ❑
No
32. Permit Expiration Date
12/31/2025
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
----
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
►1 Yes ❑ No
❑ 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. - Yes •No
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. ►-Yes ■No
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?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
►1 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 IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/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❑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?
❑ Yes ❑ No
None
❑ 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
►1
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❑NoElN/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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes // No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
The files were complete and well organized.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
2. Industry Address:
J 1
MM/DD/YY
ill I I
3. Type of Industry/Product:
4. Industry Contact:
Phone:
Fax:
Title:
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: A very well run program.
Requirements:
Recommendations:
NOD: El YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 12/09/2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

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United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 IN I 2[ I
21111111
NPDES yr/mo/day Inspection
3 I NC0026689 111 121 21/11/23 117
Type
181 p I
11111111111
Inspector Fac Type
191 S 1 201
1111111111111111111111111
r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 701 1 711 1 72 I N I 731 1 174751 1 1 1 I 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)
Denton WWTP
300 Council Access Rd
Denton NC 27239
Entry Time/Date
10:15AM 21/11/23
Permit Effective Date
21/10/01
Exit Time/Date
11:45AM 21/11/23
Permit Expiration Date
26/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Troy B Branch/ORC/336-859-4460/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Kelly Craver,PO Box 306 Denton NC 272390306/Interim Town
Manager/336-859-4231/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports • Self -Monitoring Progran Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Jim J Gonsiewski
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Docusigned by: DWR/Division of Water Quality/336-776-9704/
li... Govt,‘te-vxk-1 12/9/2021
E797B66F779045F...
Signature of
Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
iDocuSigned by:
Lo, T. 5,01tr 12/9/2021
`49A...
EPA Form 3560-31 1evE2C 414 evious editions are obsolete.
Page# 1

3I
NPDES
NC0026689
111 121
yr/molday
21/11/23
117
Inspection Type
18ID1
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On November 23, 2021 a Pretreatment Compliance Inspection (PCI) was performed by Jim
Gonsiewski of the Winston-Salem Regional Office. Troy Branch was present for the inspection. The
purpose of this inspection was to determine the effectiveness of the Town's pretreatment program,
which includes reviewing the files, POTW plant performance, industry monitoring data, and
adherence to the enforcement response plan (ERP).
Background
This is a 0.8 MGD permitted facility. The Town has one (1) Significant Industrial User (SIU) which is
not categorical. The publicly owned treatment works (POTW) has had five exceedances of
dichlorobromomethane in April 2021, May 2021, July 2021, August 2021, and September 2021. This
has been a recurring problem. The Town is actively working to eliminate this constituent. A major
renovation of the chlorine contact chamber is scheduled to begin in December 2021 and should be
completed in 2022 to eliminate this problem.
POTW Interview
There are no plant problems related to pretreatment issues and, other than dichlorobromomethane,
there are no NPDES permit limit or monitoring violations recorded from November 2020 through
November 2021. The facility is very well operated.
The pretreatment program is considered satisfactory. Mr. Branch runs an excellent pretreatment
program.
Page# 2

Permit: NC0026689
Inspection Date: 11/23/2021
Owner - Facility: Denton VWVTP
Inspection Type: Pretreatment Compliance
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑•❑
application?
Is the facility as described in the permit? ■ ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ ❑•❑
Is access to the plant site restricted to the general public? 11100111
Is the inspector granted access to all areas for inspection? M ❑ ❑ ❑
Comment:
Page# 3