NC0024112_Pretreatment Complaince Inspection_20220308

liCNORTH 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: City of Thomasville, Hamby Creek WWTP
2. Control Authority Representative(s): Misty Condor
3. Title(s): Laboratory Supervisor, Pretreatment Coordinator, ORC — WP Alum Lagoon
4. Last Inspection Date: _ 1/21/2021 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
1
MM/DD/YY
7. Current Number Of Significant Industrial Users (SIUs)?
5
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?
2 *see FRC
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
1
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
1
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)?
5
16. Number of CIUs in SNC?
2
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)
®YES ❑NO
Feb-BOD; March-BOD/TSS; July-
TSS & missed TN. *2021 - all
rain events (except TN)
❑ YES ®NO
SNC for Limits:
SNC for Reporting: Finch Industries & McIntyre
Not Published: Not yet, but working on
notice
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
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO *See FRC
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
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
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

If yes, which ones? Eliminated: Added:
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)
11-2020
/L Yes ❑ No
Pending
❑ Yes 1 No
Industrial Waste Survey (IWS)
In Progress
❑ Yes ❑ No
9/11/2015
/1 Yes ❑ No
2/28/2022 *See
FRC
Sewer Use Ordinance (SUO)
1/31/2013
L Yes ❑ No
3/25/2013
r Yes ❑ No
Enforcement Response Plan (ERP)
2/11/2020
L Yes ❑ No
2/14/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
2014*
A Yes ❑ No
1/25/2019
❑ Yes 1 No
*See FRC
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Finch
2. AMC
3. McIntyre
30. IUP Number
0018
0028
0031
31. Does File Contain Current Permit?
i1 Yes ❑ No
0 Yes ❑ No
i1 Yes ❑ No
32. Permit Expiration Date
1/31/2027
1/31/2027
6/30/2022
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
i1 Yes ❑ No
0 Yes ❑ No
i1 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?
i1 Yes ❑ No
A Yes ❑ No
i1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 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
®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❑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®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?
i1 Yes ❑ No
A Yes ❑ No
i1 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 0 No
❑ Yes A No
i1 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
NOV issued
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®No❑N/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 /1 No
❑ Yes 1 No
❑ Yes /1 No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated December 2016 Page 2

FILE REVIEW COMMENTS (FRC):
From #10:
Custom Drum and HERR was not sampled in 2021. Custom Drum's permit was cancelled January 2021. HERR had no flow.
From #22:
LTMP: Non -industry sampling is generally done bi-annually, however due to COVID-19 restrictions/issues, sampling was done once
in 2021.
From #28:
1. IWS is in progress. Ms. Conder explained Keyes allotted the program an extension and the IWS is due 3/8/2022.
2. HWA is awaiting approval letter from Division.
3. LTMP — Last approval Ms. Conder has in program files is from 2014, but DEQ records indicated LTMP last approval was 2019.
From #38a (Finch & McIntyre)
Permit Review Letters are still being processed as they were just submitted for review to Division.
From #49
All penalty collection documentation is sent to accounting department.
Note: New WWTP permit was issued (expires 4/30/2026). In the new permit are required pretreatment updates that must be completed by
September 28, 2022. LTMP/HWA/IWS/PQLs will need to be updated to reflect revisions made after technical evaluation is conducted.
This includes a review of POCs and updated LTMP to reflect in IUPs and sludge management permits. Additionally, PQLs for silver,
cadmium, lead and mercury are to be updated (Cd/Pb/Hg are recommended updates from the Division). Due to local limits being assessed,
the program will need to submit an updated Headworks Analysis. Additionally, after the EPA has finalized a wastewater method for PFAS,
the program will be required to sample for PFAS 2x year.
INDUSTRY INSPECTION ICIS CODING:
***Audit was not performed durinyi PCI. Audit is due 3/2023***.
Main Program Permit Number MM/DD/YY
1 1 1 1 1 I I I 1 l 1 1 1 l
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone:
Title:
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 El YES El NO
E. Exit Interview El YES El NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: Overall, the pretreatment program is adequate. No significant issues were found during the inspection.
Currently the pretreatment program is in the process of updating files due to new permit issuance. Inspector will return in late 2022 (after
Sept. 28' deadline) for a follow up inspection with regards to the changes needed to program since the issue of new permit.
Requirements:
Recommendations: Inspector recommends keeping a copy of penalty collections in their respective files.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Tricia Lowery DATE: 3/8/2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4