NC0055786_Compliance Evaluation Inspection_20191009

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 9, 2019
Mr. Tom Johnson — Water Resources Director.
City of Lexington
28 West Center Street
Lexington, North Carolina 27292
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Lexington
NPDES# NCO055786
Davidson County
Dear Mr. Johnson:
On September 10, 2019 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski of
the Winston-Salem Regional Office. Ms. Eglantina Minerali was present for the inspection. The purpose of
this inspection was to determine the effectiveness of the Town's pretreatment program, which includes
reviewing the files, including industrial monitoring data, POTW plant performance, industry monitoring
data, and adherence to the enforcement response plan (ERP).
Background
The City has five (5) Significant Industrial Users (SIUs), four (4) of which are categorical. The treatment
plant is permitted for 6.5 MGD.
POTW Interview
Ammonia was exceeded in June and July 2019. The composting equipment was repaired which eliminated
the exceedances.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on January 9, 2015. The HWA was approved on
June 10, 2015. The next HWA is due on January 6, 2020.
The last Industrial Waste Survey (IWS) was submitted on January 9, 2015. The IWS was approved on
February 6, 2015. The next IWS is due on April 1, 2020.
The Sewer Use Ordinance (SUO) was approved on January 9, 2013.
The Enforcement Response Plan (ERP) was approved on July 2, 2010.
The Long Term Monitoring Plan (LTMP) was approved on November 4, 2016.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

LTMP File Review
The Long Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
None of the five (5) SIUs were in significant noncompliance (SNC) in 2018.
A review of the file for ASCO (#0038) revealed that the monitoring data was well organized and compliant.
A review of the file for Matcor (#0012) revealed that the monitoring data was well organized and compliant.
A review of the file for Proctor, Inc. (#0028) revealed that the monitoring data was well organized and
compliant.
The slug control plan for ASCO (#0038) was in good order.
The slug control plan for Matcor (#0012) was in good order.
The slug control plan for Proctor, Inc. (#0028) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Minerali continues to maintain an effective
pretreatment program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
E
e-oeuBTgnMcby-
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: PERCS Unit — Monti Hassan (Electronic Copy)
Eglantina Minerali — City of Lexington (Electronic Copy)

K_CNORTH 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)l
1. Control Authority (POTW) Name: City of Lexington
2. Control Authority Representative(s): Eglantina Minerali
3. Title(s): Laboratory Supervisor/Pretreatment Program Coordinator
4. Last Inspection Date: 09/18/18 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:
ICIS CODING
Main Program Permit Number
I N I C 1 0 1 0 1 5 1 5 1 7 1 8 16 1
105155 a 1) 97YW4
1 09 1 10 1 19 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users SNs ?
0
8. Number of SNs With No NP or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SNs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SNs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
12. Number of SNs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SNs in SNC with Pretreatment Schedule?
0
14. Number of SNs on Schedules?
0
15. Current Number Of Categorical Industrial Users CNs ?
0
16. Number of CNs in SNC?
0
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 for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SNs in SNC) Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SNs 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 El NO
June -July 2019 — Ammonia.
Composting equipment repaired.
[_1 YES ® NO
Limits: None
Reporting: None
blished: None
None
❑ 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 Division Inspector, please verify
yourself!
26.
27.
If NO to 23 - 26, list violations
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 sunnortine documents and cony of PFRC...0 Annrnvnl ..Afl, Prnm nm Tnfn•
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis A
O1/09/2015
® Yes ❑ No
06/10/2015
N Yes ❑ No
O1/06/2020
Industrial Waste Survey WS
01/09/2015
N Yes ❑ No
02/06/2015
N Yes ❑ No
04/01/2020
Sewer Use Ordinance SUO
01/08/2013
N Yes ❑ No
01/09/2013
N Yes ❑ No
Enforcement Response Plan ERP
06/01/2010
Yes ❑ No
07/02/2010
N Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/07/2016
N Yes ❑ No
11/04/2016
N Yes ❑ No
INDUSTRIAL USER PERMIT FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29.
User Name Ir
1. ASCO 2. Matcor
3. Proctor, Inc.
30.
IUP Number
0012
0028
31.
Does File Contain Current Permit?
N
a05/31/202F4'l
N Yes ❑ No
Yes ❑ No
32.
Permit Expiration Date
05/31/2024
11 05/31/2024
33.
Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
11 433.15
433
F 433.15
34.
Does File Contain Permit Application Completed Within One Year Prior
N Yes ❑ No
N Yes ❑ No
N Yes ❑ No
to Permit Issue Date?
35.
Does File Contain an Inspection Completed Within Last Calendar Year?
Yes ❑ No
N Yes ❑ No
N 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❑No®N/A
pYes❑No®N/A
❑Yes❑NoON/A
Organic Management Plan (TOW)?
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?
I b.DYesivo®N/A
b.DYesONo®N/A
I b.pYesONo®N/A
39.
During the Most Recent Semi -Annual Period, Did the POTW Complete
N Yes ❑ No
N Yes ❑ No
N Yes ❑ No
its Sampling as Required by IUP, including flow?
40.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
E Yes ❑ No
N Yes ❑ No
Yes No
41.
During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes[]NoON/A
®Yes❑NopN/A
❑Yes❑No®N/A
Sampling as Required by IUP, including flow?
SIU does not
SIU does not
I
SIU does not
S
sam le
sample
41b.
During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑Yes❑No®N/A
pYes❑No®N/A
❑Yes❑No®N/A
on time?
42a.
For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
file includeprocess/dilution flows as Required by IUP?
42b.
For categorical rUs 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 b IUP?
43a.
During the Most Recent Semi -Annual Period, Did the POTW Identify
N Yes ❑ No
N Yes ❑ No
El Yes N No
All Limits Non -Compliance from Both POTW and SIU Sam lin ?
pH, now
pH
43b.
During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoON/A
❑Yes❑NoON/A
❑YesONo®N/A
All Re ortin Non-Com liance from SIU Sampling?
44.
a. Was the POTW Notified by SIU (Within 24 Hours) of All Self:
amYesoNo®N/A
a.oYesoNo®N/A
a.0Yes[3No0N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.DYesoNo®N/A.
b.[1YesONo0N/A
b.pYespNo®N/A
c. If applicable, Did POTW resample within 30 days of be aware
of SIU limit violations in the POTW's sampling of the SIU?
c�YesONo®N/A
.
e.OYesoNo®N/A
c.i3Yesr7No0N/A
46.
During the Most Recent Semi -Annual Period Was the SIU in SNC?
❑
Yes N No
❑ Yes N
No
❑Yes N
No
47.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes0No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
as Specified in the POTW's ERP OVs Penalties, timing, etc.)?
48.
Does the File Contain Penalty Assessment Notices?
❑Yest]No®N/A
❑YespNo®N/A
❑Yes❑No®N/A
49.
Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
pYes❑No®N/A
❑Yes❑NORN/A
50.
a. Does the File Contain Any Current Enforcement Orders?
a.13YesONo®N/A
a.DYesONo®N/A
a.pYes0No0N/A
b. Is SIU in Compliance with Order?
b.13Yes[3No0N/A
b.DYesONo®N/A
b.pYesONo®N/A
51.
Did the POTW Representative Have Difficulty in Obtaining Any of This
[--]Yes N No
❑ Yes N No
❑ Yes N No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated. December 2016 Page 2

FILE REVIEW COMMENTS: Good lines of communication are maintained between the facility and the SIUs. Leggett & Platt #1
stopped production on March 30, 2019. The POTW conducted a close out inspection on July 3, 2019. Leggett & Platt #2 is now called
Proctor, Inc. Matcor is upgrading their pretreatment system. ASCA was issued an NOV in March for flow and in April for pH.
Cardinal was issued a NOV in January 2019 for not checking flow in December 2018.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspecte
2. Industry Address
3. Type of Industry/
4. Industry Contact:
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 LINO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: A very well -run Program.
Requirements:
Recommendations:
NOD: ❑ YES ENO
NOV: ❑ YES M NO
QNCR: ❑ YES M NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 10/09/2019
NC D WR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3