NC0024333_Pretreatment Compliance Inspection_20170802

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y �•,6
Water Resources
Environmental Quality
Mr. Kyle Ketchum
WWTP Superintendent
City of Monroe
Post Office Box 69
Monroe, North Carolina 28111
Dear Mr. Ketchum:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZMMERMAN
Director
August 2, 2017
Subject: Pretreatment Compliance Inspection
City of Monroe
NPDES Permit No. NCO024333
Union County RECEIVED/NCDEQ/DWR
AUG 0 8 2017
Water Quadlty
Enclosed is a copy of the Pretreatment Compliance Inspection Report f0ftwidepo@ptg4he
City of Monroe's Industrial Pretreatment Program on July 25, 2017, by Mr. Wes Bell of this Office.
Please inform the City's Pretreatment Coordinator of our findings by forwarding a copy of the enclosed
report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at [phone], or via email at [e-mail].
Enclosure -
Inspection Report
cc: Monti Hassan, PERCS Unit
MSC -1617 Central -Basement
R.
Sincerely,
M
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 16 10 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
' - PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION 1Comolete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: City of Monroe
2. Control Authority Representative(s): Kyle Ketchum, Kevin Keesler
3 Title(s): WWTP Superintendent, Pretreatment Coordinator
4. Last Inspection Date: 1/14/16 Inspection Type: ® PCI ❑ Audit
a
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 ® NA
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
N NCO024333 7/25/17 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users SIUs)?
13
SNS
8. Current Number Of Categorical Industrial Users CIUs)?
8
CNS
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. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SlUs With No IUP, or With an Expired lUP
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)
1
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
1
MSNC
15. Number of SILTS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SlUs 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 SNC foi
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fon
Public Notice?(May refer to PAR if Excessive SIUs in SNC) -12/201
Not Pu
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
Flow violation for 12/2015; due
to significant rainfall events
❑ YES ® NO
Limits: None
Reporting: Glenmark Generics; 7/2016
5 time period.
blished: None
NA
❑ 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
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 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 Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (WA)
3/2/15
® Yes ❑ No
5/29/15
® Yes ❑ No
4/1/20
Industrial Waste Survey (IWS)
9/30/14
® Yes ❑ No
10/15/14
® Yes ❑ No
10/1/19
Sewer Use Ordinance SUO
12/27/12
El Yes ❑ No
1/4/13
® Yes ❑ No
❑ Yes ❑ No
Enforcement Response Plan RP
6/18/13
® Yes ❑ No
9/12/13
® Yes ❑ No
® Yes El No
Long Term Monitoring Plan (LTMP)
7/27/16
® Yes ❑ No
8/29/16
® Yes ❑ No
a. ❑Yes ❑No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29 User Name
1. ATI —Bakers South 2. 11 3.
30. IUP Number
CM -30
31. Does File Contain Current Permit?
® Yes ❑ No 11
❑ Yes ❑ Nol
❑ Yes ❑ No
32 Permit Expiration Date
6/30/20
33 Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A
471
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes El No
El Yes ❑ No
Yes ❑ No
36 a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a []Yes ❑No
a. ❑Yes ❑No
b. If No, is One Needed? (See Inspection Form from POT
b. []Yes ❑No
b. []Yes ❑No
b. ❑Yes ❑No
37 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoUN/A
❑Yes❑No❑N/A
11
❑Yes❑No❑N/A
Organic Management Plan (TOMP)9
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes [IN o
a. ❑Yes ❑No
a. []Yes []No
b. All Issues Resolved?
b ❑Yes❑No®N/A
b ❑Yes❑No❑N/A
b ❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain-Of-Custod Forms?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
11
❑Yes❑No❑N/AjF57e_s[3No0N/A
1
Sampling as Required by ATP, including flow?
41b During the Most Recent Semi -Annual Period. Did SIU submit all reports
®Yes❑No❑N/A
❑Yes❑No❑N/A❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
42b For categorical IUs with Production based iimits, does file include
❑Yes❑No®N/A
111
❑Yes❑No❑N/A
❑Yes❑No❑N/A
11 1
production rates and/or flows as Required by IUPC
43a During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑NA
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Limits Non -Com Bance from Both POTW and SIU Sampling?
43b. During the,Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a ®YespNo❑N/A
a.❑Yes❑No❑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❑No❑N/A
c. Did POTW resample within 30 days of knowledge of SILT limit
c ❑Yes❑No®N/A
e ❑Yes❑No❑N/A
c ❑Yes❑No❑N/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I ❑ Yes ® No
11 ❑ Yes ❑ No
11 ❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®YespNo❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc.)?
47. Does the File Contain Penal Assessment Notices?
❑YespNoRN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection
❑YespNo®N/A
11 ❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑YespNo❑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❑NanN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ❑ No
❑ Yes ❑ No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
28. The SUO was adopted on 5/21/13.
35. POTW performed ATI inspection on 11/4/16.
37. ATI has previously submitted TOMP (due to IUP TTO monitoring requirement) and TTO Certifications were received on 6/21/17,
11/1/16, and 6/7/16.
39. POTW contracts Shealy Environmental Services and GEL Labs (low level mercury) for sample analyses.
41a. ATI contracts Pace Analytical Services for sample analyses.
46. POTW issued Notice of NonCompliances to ATI for a flow limit violation (Pipe 02) in January 2017 and a chromium limit violation
(Pipe 01) in May 2017.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type
❑N N C 0 0 2 4 3 3 3 07 25 17 0
(DTIA) (TYPI)
1. Industry Inspected: ATI — Bakers South Operations
2. Industry Address: 3875 Aeropointe Parkway, Monroe, N.C. 28110
3. Type of Industry/Product: 471/Forming/Forging Metals
4. Industry Contact: Scott Ryan Title: EHS Manager Phone: [phone] Ext. 3470
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:
Inspector
Facility Type
2❑
(INSP)
(FACC)
The facility currently has approximately 125 employees and operates 24/7. The pretreatment system is staffed with wastewater operators during
first shift only. The Pretreatment wastewater system includes the following: holding tanks; pH adjustment; chemical precipitation; flocculation;
clarification, flow measurement; and filter press Dewatered wastewater solids are disposed at the Anson County Landfill.
Used oils are disposed by a contracted company (Wallace).
The Pretreatment wastewater system appeared to be properly operated and well maintained. The records reviewed during the inspection were
organized and well maintained.
NC DWR Pretreatment Compliance Inspection (PCI) Form IJpdated 7/25/07 Page 3

SUMMARY AND COMMENTS:
The POTW staff must ensure that the contracted laboratories meet the minimum detection limits for molybdenum (IUP) and copper (LTMP —
March 2017 sampling event).
The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was being
properly implemented.
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW' Rating:
Satisfactory ® Marginal ❑ Uns ' factory_ ❑
PCI COMPLETED BY: tZ DATE: August 1, 2017
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4