NC0086550_Pretreatment Inspection_20190318

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MICHAEL S.REGAN •. "`��" ,,4r� MAR 2 7 2019
Secret �A::
LINDA CULPEPPER NORTH CAROE 1NA Water Rezourcez
Orr Environmental Quality P rmiging Section
March 18, 2019
Johnny J Britt
Town of Fairmont
PO Box 248
Fairmont, NC 28340-0248
SUBJECT: Pretreatment Compliance Inspection Report
Fairmont Regional WWTP
NPDES WW Permit No. NC0086550
Robeson County
Dear Mr. Britt:
Enclosed please find a copy of the Pretreatment Compliance Inspection form from the inspection conducted on
March 6, 2019. The Pretreatment Compliance Inspection was conducted by Johnathan Watts, Environmental
Specialist, of the Fayetteville Regional Office.
The purpose of the pretreatment inspection is to determine the effectiveness of the Pretreatment program by
reviewing the files, which include a review of POTW plant performance, sampling and compliance judgment program,
adherence to the enforcement response plan (ERP), and evaluating how the program performs an industrial user
inspection. This PT Inspection report indicated that the City of Fairmont Pretreatment Program met the pretreatment
requirements as outlined in 15A NCAC 2H .0900
The inspection report is attached with findings and observations made during the inspection. Please review for
more detail.
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If you should have any questions, please do not hesitate to contact Johnathan Watts with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3322 or via email at
johnathan.watts©ncdenr.gov.
Sincerely,
/1,,f,ti,)/,,-Z/e- ----
J. Trent Allen, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ __
Cc: Fayetteville Regional Office — (JW)
PERCS Unit '
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United States Environmental Protection Agency Form Approved
EPA Washington,D C 20460 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 -�IN 2 IL I 3 I NC0086550 111 12 1 19/03/06 117 18 I!:]
19 ISI 201
21IItI I I I I I III I I I I I I I I I I I I I I I I I I I I I I III I I I I l f6
Inspection Work Days Facility Self-Monitoring Evaluation Rating _ B1 QA — --Reserved
671 I 701 I 711 I 72 I N I 73I I 174 75I1 I I I 111180
Section B.Facility Data LJ
Name and Location of Facility Inspected(For lndustnal Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) S 10 OOAM 19/03/06 15/11/01
Fairmont Regional W /TP
Exit Time/Date Permit Expiration Date
Off US Hwy74
0100PM 19/03/06 19/07/31
Fairmont NC 28340
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Kevin H Taylor/ORC/910-734-7301/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Johnny J Britt,PO Box 248 Fairmont NC 283400248/Superintendent/910-628-0064/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
I. 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
)3.,VJohnathan C Watts FRO WQ//910-433-3300/ G. T)s---- 7(A-I tei
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers �,� Date
Trent Allen FRO WQ//910-433-3300/ s G �E -' T 2-2-47
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type (Cont) 1
31
_ NC0086550 111 121 19/03/06 J 17 18 i D i
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Fairmont has one(1) significant industrial user(SIU),which is categorical and is a 1 75 MGD permitted
facility.
One permit file was reviewed.The pretreatment inspection file review included Harger Inc Harger is a
categorical significant industrial user that uses process wastewater for Rod breakdown,Annealing and
electroplating,for lighting protection and grounding equipment
Please ensure slug/spill control plan is updated as necessary in case of an accidental spill,
preventative actions and control mechanisms can be put in place to avoid potential interference or in
any other way violate the POTW's permit conditions.
Fairmont no longer holds a land application permit.Therefore,the STMP may be modified to remove
those pollutants of concern associated with holding a land application permit arsenic, molybdenum
and selenium
The Division of Water Resources commends Ms Blackwell, Mr Kevin Taylor and Mr. Johnny Britt for
their initiative and proactive approach towards documentation and monitoring. They are implementing
the Pretreatment Program in a consistent and professional manner and the time and professional
courtesy extended during the inspection is greatly appreciated
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me by phone at(910)433-3322 or email at Johnathan [e-mail] if you have any
questions or concerns
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
lov'ore:Resow ces
BACKGROUND INFORMATION [Complete Prior To PCI;Review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name:Town of Fairmont
2. Control Authority Representative(s):Nadine Blackwell,Kevin Taylor,Johnny Britt
3. Title(s):PT Coordinator
4. Last Inspection Date: 07/06/2017 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
1N1C101018161515101103106 [191
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)? 1
16. Number of CIUs in SNC? I 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑YES ® NO
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 ❑YES ®NO
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 for Limits:None
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:None
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? None
21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ® NO
Ones?
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 yourself
26. IfNO 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:Molybdenum,Arsenic, Selenium Added:
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 Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 03/30/2016 ®Yes ❑ No 06/20/2016 ®Yes ❑ No 04/01/2021
Industrial Waste Survey(IWS) 06/12/2015 ® Yes ❑ No 08/18/2015 ®Yes ❑ No 07/01/2020
Sewer Use Ordinance(SUO) 02/25/2013 ® Yes ❑ No 03/21/2013 ®Yes ❑ No
Enforcement Response Plan(ERP) 09/03/2010 ®Yes ❑ No 12/01/2010 ®Yes ❑ No
Long Term Monitoring Plan(LTMP) 12/08/2014 ®Yes ❑ No 12/18/2014 ®Yes ❑ No 09/30/2019
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Harger Inc. 2. 3.
30. IUP Number
31. Does File Contain Current Permit? ®Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No
32. Permit Expiration Date 03/01/2022
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 468-H,J,K,M
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 ❑ No ❑ Yes ❑ No ❑Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ZYes ❑No a. EYes❑No a. DYes ❑No
b.If No, is One Needed?(See Inspection Form from POTW) b. EYes ❑No b. ['Yes ❑No b. EYes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No 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-Custody Forms? ®Yes ❑ No ❑ Yes ❑ No ❑Yes ❑ No
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Sampling as Required by IUP,including flow?
41b.During the Most Recent Semi-Annual Period,Did SIU submit all reports NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP9
42b. For categorical IUs with Production based limits,does file include NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify NYes❑No❑N/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.❑Yes ONo❑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.If applicable,Did POTW resample within 30 days of becoming aware o❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU? c❑Yes❑No❑N/A c❑Yes❑No❑N/A
46. During the Most Recent Semi-Annual Period, Was the SIU in SNC? ❑Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No
47. During the Most Recent Semi-Annual Period, Was Enforcement Taken NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing, etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
50. a. Does the 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❑NoNN/A b❑Yes❑No❑N/A b❑Yes❑No❑N/A
51. 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 December 2016 Page 2

FILE REVIEW COMMENTS:
All files were available for direct access.Excellent records management.
47. NOV was issued on July 25,2018 because Harger did not meet the self-monitoring requirement for January through June 2018.Although
Harger missed the submission for the first compliance period,a makeup sample was submitted on July 19,2018.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
f Nf C10 10 18 16 15 15 10 1 f03106119 [
1. Industry Inspected: Harger Inc.
2.Industry Address: 12779 HWY 130 East Business,Fairmont NC 28340
3.Type of Industry/Product:Manufacturing of lightning protection and grounding equipment
4. Industry Contact: Kurt Holmes/Brian C.Hayes Title: Engineering Leader/Manufacturing Operations Manager
Phone[phone];Cell(847)533-2511
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
B. Plant Tour YES
C. Pretreatment Tour YES
D. Sampling Review YES
E. Exit Interview YES
Industrial Inspection Comments:
Majority of byproduct is process and wash down wastewater from Rod breakdown, annealing and electroplating. These metal finishing
processes are covered under 40CFR468. Discharge is monitored prior to introduction of domestic wastewater.Ensure that IU has most recent
spill plan updated as necessary.
OVERALL SUMMARY AND COMMENTS:
Recommendations: Fairmont no longer holds a land application permit. Therefore,the STMP may be modified to remove those POCs
associated with holding a land application permit: arsenic,molybdenum and selenium.
NOD: NO
NOV: NO
QNCR: NO
POTW Rating: Satisfactory
PCI COMPLETED BY: Johnathan C.Watts,FRO DATE: 03/06/2019
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3