NC0024571_Pretreatment Audit Report_20150622

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor Donald R. van der Vaart
Secretary
June 22,2015
Mr. Steve West.
Pretreatment Coordinator
City of Lumberton
P.O. Box 1388
Lumberton,NC 28359
SUBJECT: Pretreatment Audit Report
Lumberton WWTP
NPDES Permit#NC0024571
Robeson County
Dear Mr. West:
Enclosed please find a copy of the Pretreatment Audit Report from the inspection conducted on June 11, 2015
by Trent Allen of the Fayetteville Regional Office and Monti Hassan of the PERCS Unit. Also, I would like to
thank Mrs. Beverly Allen for her time and cooperation during the inspection. The facility was found to be in
Compliance with the pretreatment requirements as outlined in 15A NCAC 2H .0904 for Pretreatment Programs.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff has
any questions,please call me at 910-433-3336.
Sincerely,
e- 7.Ae /fg-//4"
Trent Allen
Assistant Regional Supervisor
Division of Water Resources
Water Quality Regional Operations Section
cc: PERCS Unit
FRO Pretreatment Files (TA)
Fayetteville Regional Office
225 Green Street,Suite 714,Fayetteville,North Carolina 28301-5095
Main Phone: [phone] \ Internet: http:/lwww.ncdenr.gov
An Finial nnnnrh,nity V Affirmative Anitnn FmnlnvAr—Marla in nart by Rnnvniail Pamir

United States Environmental Protection Agency Form Approved.
EPA Washington,D.C.20480 OMB No.2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A:National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 i u j 2 15 l 3 I NC0024571 111 12 15/06/11 117 18 LI 19[, J 20U
21111111 1111111 1111 1 11 1111 1 1 11111 111111111 I I r
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----Reserved---
67I I 701 L_1 I 71 I ilI 72 12
u I 731 1 174 751 1 1 1 1 1 1 180
Section B:Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 10:00AM 15/06/11 11/04/01
Lumberton WWTP
Exit Time/Date Permit Expiration Date
700 Lafayette St Extension
01:00PM 15/06/11 14/07/31
Lumberton NC 28359
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Ill
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Wayne Home,501 E 5th St Lumberton NC 28358/1910-671-3806/9106713814
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
II Pretreatment
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Trent Ailerrc--�� 044 FRO WQ//910-433-3300/ 22-""./
Monti Hassan Pretreatment Unit///
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
B in S H son_41 94 FR WQ//910-433-3300 Ext.72E -If- a d _ IS.
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NC0024571 111 12I 15/06/11 I 17 18 i r
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The Pretreatment Audit was conducted on June 11,2015 at the City of Lumbertons WWTP. Steve
Westand Beverly Allen with the City were present along with Monti Hassan with the PERCS Unit.The
inspection included an audit of Kayser-Roth(IUP#004)The inspection report indicates that the City of
Lumberton met the pretreatment requirements as outlined in 15A NCAC 2H .0900 for Local
Pretreatment Programs.
Page# 2

NCNORTH CAROLINA DIVISION OF WATER RESOURCES
DENRPRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: City of Lumberton
2. Control Authority Representative(s): Steve West,Beverly Allen
3. Title(s):Pretreatment Coordinator/Pretreatment Officer
4. Address of POTW:
Mailing 700 Lafayette St.
City Lumberton Zip Code
Phone Number 910-671-3858 Fax Number 910-671-3932 E-Mail swest(aici.lumberton.nc.us
5. Audit Date 06/11/2015
6. Last Inspection Date:02/19/2014 Inspection Type: ®PCI ❑Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ®Yes ❑ No
If No,Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑Yes ® No
If Yes,Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes ❑ No ® NA
Parameters Covered Under Order
PCS(WENDB)Coding
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
INI INICIO 10 12 14 15 17 I1 I 106111 I20I IGI ISI I1 I
(DTIA) (TYPI) (1NSP) (FACC)
10. Current Number of Significant Industrial Users(SIDS)? 6 SIUS
11. Current Number of Categorical Industrial Users(CNS)? 1 CNS
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0
14. Enter Higher Number of 12 or 13 0 NOIN
15. Number of SIUs with No IUP,or with an Expired IUP 0 NOCM
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 0 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
17. Number of Sills in SNC for Reporting During Either of Last 2 Semi-Annual Periods 0 MSNC
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods 0 SNPS
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0
Semi-Annual Periods
20. Number of SIUs in SNC for Self-Monitoring Requirements that were Not Inspected or Sampled 0 SNIN
•
NC DWR Pretreatment Audit Form Revised: July 25,2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW-Review POTW files,verify POTW has copy of each Program Element
in their File,complete with all supporting documents and PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Dne,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 7-3-14 ®Yes❑ No 9-18-14 ®Yes❑ No 9-1-19
Industrial Waste Survey(IWS) 9-2-10 0 Yes❑ No 11-4-10 " 0 Yes-0 No 9-1-15
Sewer Use Ordinance(SUO) 8-21-12 ►.1 Yes❑ No 9-17-12 0 Yes 0 No
Enforcement Response Plan(ERP) 7-31-09 El Yes 0 No 10-13-09 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 5-15-13 ®Yes❑ No 8-2-13 ®Yes❑ No
Legal Authority(Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
®Yes❑ No If yes,Please list these towns and/or areas.Robeson County Landfill,Trinty
23. If yes to#22,Do you have current Interjurisdictional Agreements(LTAs)or other Contracts? ®Yes❑ No ❑NA
A copy,if not already submitted,should be sent to Division.IUP's only.
24. If yes to#22,Have you had any trouble working with these towns or districts? ❑Yes® No ❑NA
If yes,Explain.
25. Date of Last SUO Adoption by Local Council 2/11/13
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ®Yes 0 No
If no,POTW must send copy within 30 days.Sent with the new IUP in 2013.
28. Have you had any problems interpreting or enforcing any part of the ERP(i.e.any adjudication,improper enforcement,etc?
❑Yes® No If yes,Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®S❑M❑U
Access to POTW Vehicles for
Sampling,Inspections,and ®S OM❑U
Emergencies
Access to Operable Sampling
Equipment ®S❑M❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis ®S OM❑U
Reference Materials
®S❑M❑U
Staff Training(i.e.Annual and
Regional Workshops,Etc.) 1/S❑M❑U
Computer Equipment(Hardware and
Software) ®S❑M Du
NC DWR Pretreatment Audit Form Revised: July 25,2007 p,(,.

31. Does the POTW have an adequate data management system to run the pretreatment program?®Yes 0 No
Explain Yes or No.
32. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Surcharges Hauled waste is billed per gallon
Public Perception/Participation
33. Are there any local issues affecting the pretreatment program (e.g..odor,plant closing,new or proposed plants)?
❑Yes® No If yes,Explain.
34. Has any one from the public ever requested to review pretreatment program files? 0 Yes® No
If yes,Explain procedure.If no,How would the request be addressed?
35. Has any industry ever requested that certain information remain confidential from the public? ❑Yes® No If yes,Explain
procedure for determining whether information qualified for confidential status,as well as procedure for keeping files confidential
from public. If no.how would the request be addressed?.
36. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes El No
Yearly
37. Is the public notified about changes in the SUO or Local Limits? ®Yes El No
Online and local paper
38. Were all industries in SNC published in the last notice? ®Yes 0 No
Permitting(Industrial Waste Survey-IWS)
39a...How does the POTW become aware of new or changed Users?Inspections Department/City Hall
39b.Once the POTW becomes aware of new or changed Users,how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?)Send application and determine from that,and the IWS
40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
❑Yes No If Yes,How many are there?
Please list each site and how it is permitted,if applicable.
41. Does the POTW accept waste by(mark if applicable) ®Truck ❑Dedicated Pipe ❑NA
42. If the POTW accepts trucked waste,what controls are placed on this waste? (example.designated point,samples drawn,
manifests required)pH,smell test,all truck waste is placed before head works.
43. How does the POTW allocate its loading to industries?Mark all that apply
❑Uniform Limits ®Historical Industry Need ❑By Surcharge ®Categorical Limits ❑Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? El Yes® No
If yes,What parameters are over allocated?
45. If yes to#43,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
46. Does the POTW keep pollutant loading in reserve for future growth/safety? ®Yes❑ No
If yes,what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation?(for example:adjudication by an industry) 0 Yes® No
If yes,Explain.
48. How does the POTW decide on which pollutants to limit in the permits?Monitor for? (for example:were only those pollutants
listed on the application limited;categorical parameters;NPDES Pollutants of Concern)
By the application and by sampling
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Past sampling events and data received determines how often they would be sampled
NC DWR Pretreatment Audit Form Revised: July 25,2007 Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑Yes® No
If yes,which industries? What was(will be)the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance.This should include compliance judgment on all violations of limits,reporting
requirements,and permit conditions,as well as for SNC.Captains computer program is used to flag violations.If the POTW
gets a violation from sampling,they resample within 30 days.
52. Does the POTW use the Division's model inspection form or valent? ®Yes 0 No
If no,does the POTW form include all Division data? 0 Yes No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ®Yes❑ No
If no,Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All IUP's are required to have one.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Inspection of the SIU for the potenial of a slug/spill and adequacy of the control.
56. How does the POTW decide where the sample point for an SIU should be located?
Safety of personnel and process effluent only.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment;swirling the sample bucket uniformly)
POTW: ®Yes 0 No SIU: ®Yes❑ No If yes,Explain.The same sampler is used by both the POTW and
industry,but with different collection container.Sampler is set at 15 ml/15 mins.
58. Who performs sample analysis for the POTW for Metals Environmental 1
Conventional Parameters POTW
Organics Environmental 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
The POTW has their own C.O.C.sheet they use,and the commercial lab has theirs.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES 0 NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES 0 NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®YES 0 NO Is Table Adequate? 0 YES ❑NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)?®YES❑NO Division Inspector,verify yourself!
60e. If NO to any above,list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? 0 YES Z NO
If yes,which ones?Eliminated: Added:
61. Do you complete your own headworks analysis(HWA)? 0 Yes® No
If no,Who completes your HWA?Wooten Company Phone( )
62. Do you have plans to revise your HWA in the near future? 0 Yes® No
If yes,What is the reason for the revision?(mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ['Resolve over allocation 05 year expiration ❑Other
Explain.
63. In general,what is the most limiting criteria of your HWA? ❑Inhibition 0 Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future(Example:obtaining more land for sludge disposal)? 0 Yes® No
Explain.
Summary
NC DWR Pretreatment Audit Form Revised: July 25,2007 Pale 4

65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC T1W12 Pretreatment Audit Form Revised: July 25.2007 Page 5

INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1.Buckeye 2.Kayser-Roth .Elk
3ay
67. IUP Number 018 004—7 001
68. Does File Contain Current Permit? Yes No Yes No ►� Yes • No
69. Permit Expiration Date I 3/31/2018 3/31/2018 3/31/2018
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A
71. Does File Contain Permit Application Completed Within One Year PriorYes No Yes No ❑Yes ® No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year? ®Yes ❑ No EI Yes 0---NO-1 ®Yes ❑ No
73. a.Does File Contain Slug/Spill Control Plan? a. ®Yes ONo a. ®Yes ONo a. ®Yes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b.❑Yes ONo b.DYes ONo b. ❑Yes ONo
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic DYes❑No®N/A ❑Yes❑No o N/A ❑YesDNo®N/A
Organic Management Plan(TOMP)?
75. a.Does File Contain Original Permit Review Letter from Division? a. ®Yes ONo a. ®Yes ONo a.®Yes ONo
b.All Issues Resolved? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ®Yes ❑ No ®Yes 0 No El Yes ❑ No -
Sampling as Required by RIP,including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes f] No ®Yes ❑ No El Yes 0 No
78. During Most Recent Semi-Annual Period,Did SRI Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by RIP,including Flow?
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑NoDN/A ®Yes❑No❑N/A ®Yes❑No❑N/A
time?
80a.For categorical IUs with Combined Wastestream Formula(CWF),does DYes❑No®N/A ❑Yes❑No0N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
80b.For categorical IUs with Production based limits,does file include DYes❑NooN/A ❑Yes❑No®N/A ❑YesDNo®N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ®Yes El No I ®Yes 0 No ®Yes ❑ No
Limits Non-Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ®Yes❑No❑N/A ®Yes❑No❑N/A ' ®Yes❑NoDN/A
Reporting Non-Compliance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes❑No®N/A a.❑Yesallo®N/A a.❑Yes❑No®N/A
Monitoring Violations?
b.Did Industry Resample and submit results to POTW within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑NoNN/A
c.If applicable,did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU? c❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? El Yes ►Z/ No 0 Yes ® No 0 Yes ® No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑No®N/A, ❑Yes❑No®N/A ❑Yes❑No®N/A
Specified in POTW's ERP(NOVs,Penalties,timing,etc.)?
86. Does File Contain Penalty Assessment Notices? I ❑Yes❑NooN/A I ❑Yes❑No®N/A J ❑YesDNo®N/A
87. Does File Contain Proof Of Penalty Collection? ( DYes❑No®N/A I ❑Yes❑No®N/A ❑Yes❑No®N/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑No®N/A
b.Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑Yes ® No in Yes ® No ❑Yes ►1 No
Information For You?
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: July 25,2007 PRap A

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
I N1 NICIO to I2 4 I5I7I1 I 16 1111151 1 I I Ls_I I 2 I
(DTIA) (TYPI) (INSP) (FACC)
1.Industry Inspected: Kayser-Roth Corporation
2.Industry Address: 3707 West 5th Street
3.Type of Industry/Product: Textile
4.Industry Contact: Adolfo Garza Title: Facility Maintenance Phone: [phone] Fax: [phone]
5.Does the POTW Use the Division Model Inspection Form or Equivalent? El Yes ❑ No
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ®Yes 0 No
B. Plant Tour ®Yes 0 No
C. Pretreatment Tour ®Yes ❑ No
D. Sampling Review ®Yes 0 No
E. Exit Interview ®Yes ❑ No
Industrial Inspection Comments:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements:
Recommendations:
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Marginal 0 Unsatisfactory❑
Audit COMPLETED BY: Trent Allen—FRO,Monti Hassan DATE:June 11,2015
Monti Hassan,PERCS,and Trent Allen,Fayetteville Regional Office
NC DWR Pretreatment Audit Form Revised: July 25,2007 Page 7