NC0024571_Pretreatment Inspection_20190308

ROY COOPER li- 1,-:-
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MICHAEL S.REGAN - ,,A, .1
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L1NDA CULPEPPER NORTH CAROLINA g Section
Director Environmental C ua#UUy
March 08, 2019
Corey Walters
City of Lumberton
PO Drawer 1388
Lumberton, NC 28359-1388
SUBJECT: Compliance Inspection Report
Lumberton WWTP
NPDES WW Permit No. NC0024571
Robeson County
Dear Mr. Walters:
Enclosed please find a copy of the Pretreatment Compliance Inspection form from the inspection conducted on
March 5, 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 Lumberton 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
[e-mail].
Sincerely,
7
--,ZA741,11
J. Trent Allen, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Fayetteville Regional Office — (Johnathan Watts)
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 FacType
1 IN I 2 I� I 3 I NC0024571 111 12 I 19/03/05 117 18 I o] 19 I s I 201
21 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I l66
Inspection Work Days Facility Self-Monitonng Evaluation Rating B1 QA -Reserved t
67I I 70I I 71 I 1 72 I N I 731
I 17471
I I I I I I 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) 09.30AM 19/03/05 17/08/01
Lumberton WWTP
Exit Time/Date Permit Expiration Date
700 Lafayette St Extension
12 00PM 19/03/05 22/07/31
Lumberton NC 28359
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Harold Walton,PO Drawer 1388 Lumberton NC 283591388/ORC/910-671-3859/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
IN 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
Johnathan C Watts FRO WQ//910-433-3300/ . V I
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers �� Date z.
Trent Allen FRO WQ//910-433-3300/ --1'2"V .',,�� 4 4"/
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete ��YY
Page# 1

NPDES yr/mo/day Inspection Type 1
(Cont)
31
NC0024571 I1 21 19/03/05 117 18
ls Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Lumberton has seven (7)significant industrial users (SlUs), one of which are categorical and is a 20
MGD permitted facility
Three permit files were reviewed The pretreatment inspection file review included Lumberton
Cellulose, Elkay Southern Corporation and International Paper.
Kayser-Rooth Corporation,which was not part of the file review was in SNC for TRC limit violations for
BOD during January to June of 2018. Issue has been resolved and public notice was published on
February 1, 2019 in the Robesonian.
In order to update records with the Division of Water Resources, please complete and submit the
enclosed change of ownership form with the current information to reflect the correct responsible
official.
The Division of Water Resources commends Ms Allen for her initiative and proactive approach
towards documentation and monitoring. Mrs Allen is implementing the Pretreatment Program in a
consistent and professional manner and the time and professional courtesy she 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.watts@ncdenr gov if you have any
questions or concerns
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
Water Rosota cs
BACKGROUND INFORMATION[Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Lumberton
2 Control Authority Representative(s):Tammy Smith/Beverly Allen
3. Title(s): Environmental Laboratory Supervisor/Pretreatment 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
f NICIO 10 [ 214151711 i 103I05f19L
7. Current Number Of Significant Industrial Users(SIUs)? 7
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-AnnualPeriods? 1
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? 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: 1
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 None
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 ❑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 yourselfl
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: 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) 07/03/2014 ® Yes ❑ No 09/18/2014 ® Yes ❑ No 09/01/2019
Industrial Waste Survey(IWS) 08/25/2015 ® Yes❑ No 11/20/2015 ®Yes ❑ No 09/01/2020
Sewer Use Ordinance(SUO) 08/21/2012 ® Yes ❑ No 09/17/2012 ®Yes ❑ No
Enforcement Response Plan(ERP) 07/31/2009 ® Yes ❑ No 10/13/2009 ®Yes ❑ No
Long Term Monitoring Plan(LTMP) 02/23/2017 ® Yes ❑ No 05/04/2017 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Lumberton Cellulose 2. Elkay 3.International Paper
30. IUP Number 018 001 019
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 03-31-2023 03/31/2023 03/31/2023
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A N/A N/A
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. ❑Yes ENo a. ZYes ❑No a. ❑Yes ENo
b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes ENo b. ❑Yes ❑No b. ❑Yes ENo
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoEN/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. EYes❑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 ®Yes❑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 ®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 by IUP?
42b. For categorical IUs with Production based limits,does file include ❑Yes❑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 ❑Yes❑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❑No®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❑NoON/A b.®Yes❑No❑N/A
c.If applicable,Did POTW resample within 30 days of becoming aware c❑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 ®Yes❑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❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection9 ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoEIN/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❑No®N/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.
- Elkay's IUP was modified April 16,2018 to increase zinc limit from 1.6 lbs/day to 2.75 lbs/day.NOV was issued January 2018.
- Lumberton Cellulose's IUP was modified April 16,2018 to increase flow from.400 MGD to.700 MGD
- International Paper's IUP was modified May 21,2018 to increase copper and zinc to 4.01bs/day.NOV was issued January
2018 for exceeding Copper.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
j NICIO 10 1 2 1 4 1 5 17 11 1 03 105 1 19 1
1.Industry Inspected:
2. Industry Address:
3.Type of Industry/Product:
4.Industry Contact: Title:
Phone: 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 ❑ YES ❑NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments.
A formal inspection was not performed.
OVERALL SUMMARY AND COMMENTS:
•
Comments:
17. POTW NPDES limit violations include weekly fecal average for October, November of 2017, and September 2018. Ammonia
weekly and monthly average in October 2018 and TSS in December 2018. All violations possibly were associated with inclement
weather and relevance to I&I.
NOD: NO
NOV: NO
QNCR: NO
POTW Rating: Satisfactory
PCI COMPLETED BY: Johnathan Watts,Fayetteville RO DATE: March 5,2019
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3

Water Resources
ENVIRONMENTAL OUALITY
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
PERMIT NAME/OWNERSHIP CHANGE FORM
I. CURRENT PERMIT INFORMATION:
Permit Number: NCOO / / / / or NCG5 / / /. /
1. Facility Name:
II. NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
b. Name change only
c. Other (please explain):
2. New owner's name (name to be put on permit):
3. New owner's or signing official's name and title:
(Person legally responsible for permit)
(Title)
4. Mailing address: City:
State: Zip Code: Phone: (
E-mail address:
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION UNLESS ALL OF THE
APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a property deed, articles of
incorporation, or sales agreement)
[see reverse side of this page for signature requirements]
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, NC 27699-1617
919 807 6300 919-807-6389 FAX
https://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/npdes-wastewater-permits

NPDES Name & Ownership Change
Page 2 of 2
Applicant's Certification:
I, , attest that this application for a
name/ownership change has been rev ewed and is accurate and complete to the best of my
knowledge. I understandthat if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: Date:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DEQ / DWR / NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 11/2017