NC0026689_Inspection_20191223

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Troy Branch
Pretreatment Coordinator
Town of Denton
P.O. Box306
Denton, North Carolina 27239
NORTH CAROLINA
Environmental Quality
December 23, 2019
SUBJECT: Pretreatment Compliance Inspection (PCI)
Town of Denton
NPDES# NC0026689
Davidson County
Dear Mr. Branch:
On November 20, 2019 a Pretreatment Compliance Inspection (PCI) was performed by Jim
Gonsiewski of the Winston-Salem Regional Office. Mr. Steven Abercrombie and Mr. Troy Branch
were 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, POTW plant performance,
industry monitoring data, and adherence to the enforcement response plan (ERP).
Background
This is a 0.8 MGD permitted facility. The Town has one (1) Significant Industrial User (SIU)
which is not categorical. The publicly owned treatment works (POTW) has had exceedances of
dichlorobromomethane. This has been a recurring problem and the Town is actively working to
eliminate this constituent. The concentrations have been significantly reduced.
POTW Interview
There are no plant problems related to pretreatment issues and, other than dichlorobromomethane,
there are no NPDES permit limit or monitoring violations recorded from October 2018 through
October 2019. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on September 7, 2016. The HWA was
approved on November 10, 2016. The next HWA is due on September 1, 2021.
D_E Q North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
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a,+mi.mnunim,.�uwen 336.776.9800

The last Industrial Waste Survey (IWS) was submitted on March 6, 2015. The IWS was approved
on June 2, 2015. The next IWS is due on March 15, 2020.
The Sewer Use Ordinance (SUO) was approved on January 18, 2013.
The Enforcement Response Plan (ERP) was approved on December 4, 2018.
The Short Term Monitoring Plan (STMP) was approved on October 24, 2017.
STMP File Review
The STMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
The SIU was in compliance in 2019.
A review of the file for Century Hosiery (#0001) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Century Hosiery (#0001) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Branch runs an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
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Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Attachment: Pretreatment Compliance Inspection Report
cc: PERCS Unit — Monti Hassan (Electronic Copy)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Town of Denton
2. Control Authority Representative(s): Steven Abercrombie
3. Title(s): Pretreatment Operator
4. Last Inspection Date: 10/16/18 Inspection Type (Check One): M PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? M YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES M NO
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
I N I C 10 10 1 216 1618 19 1
MM DD/YY
1 11 1 20 1 19 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users SNs ?
8. Number of SNs With No NP, or With an Expired NP?
0
9. Number of SNs 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 SIUs in SNC with Pretreatment Schedule?
0r�
14. Number of SIUs on Schedules?
I�
15. Current Number Of Categorical Industrial Users CIUs ?
16. Number of CIUs in SNC?
E 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 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?
Ti,,Jhnlo
S❑NOobromomethane in 7/19,9/19,
9
❑ YES M NO
Limits: None
Reporting: None
blished: None
None
❑ YES M NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? M YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? M YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? M YES ❑ NO Is Table Adequate? M YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? M YES ❑ NO Division Inspector, please verify
yourself.
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES M NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page I

28. PRETREATMENT PROGRAM ELEMENTS REVIEW — Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and covv of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis WA
09/07/2016
M Yes ❑ No
11/10/2016
M Yes ❑ No
09/01/2021
Industrial Waste Survey IWS
03/06/2015
M Yes ❑ No
06/02/2015
M Yes ❑ No
03/15/2020
Sewer Use Ordinance SUO
01/04/2013
M Yes ❑ No
01/18/2013
M Yes ❑ No
Enforcement Response Plan RP
11/02/2018
M Yes ❑ No
12/4/2018
M Yes ❑ No
Short Term Monitoring Plan (STMP)
08/09/2017
M Yes ❑ No
10/24/2017
M Yes ❑ No
INDUSTRIAL USER PERMIT (HIP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Century Hosiery
2.
3.
30. IUP Number
0001
00
31. Does File Contain Current Permit?
M Yes ❑ No
❑Yes ❑ NoI
❑ Yes ❑ No
32. Permit Expiration Date
12/31/2019
��
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A��
34. Does File Contain Permit Application Completed Within One Year Prior
M Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
M Yes ❑ No
❑Yes
❑
NoI
El Fes ❑ 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
❑YesONo®N/A
pYesONoON/A
❑Yes❑NoON/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.OYesONoON/A
b.OYesONoON/A
b.OYesONoDN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
M Yes ❑ No
❑Yes ❑ No
❑Yes ❑ No
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
M Yes ❑ No
I
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
OYespNo®N/A
❑YespNoON/A
pYesONoON/A
Sampling as Required b ]UP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑YespNo®N/A
OYespNopN/A
pYesONoON/A
on time?
42a. For categorical fUs with. Combined Wastestream Formula (CAT), does
❑YespNo®N/A
❑YespNopN/A
pYesONoON/A
file includeprocess/dilution flows as Required by HJP9
42b. For categorical IUs with Production based limits, does file include
OYesONo®N/A
❑YesONoON/A
❑Yes❑NopN/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 SILT Sampling?
N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑YesONo®N/A
pYes❑NopN/A
❑YespNopN/A
All Reporting -Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.oYesoNo®N/A
a.oYesoNooN/A
a.pves11NooN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.OYesONo®N/A
b.OYesONoON/A
b.OYesONooN/A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
c.OYesONOON/A
c.oYesoNooN/A
c.OYesONopN/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
M
No
❑
Yes
❑
No
❑ Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
OYes❑No®N/A
❑Yes❑No❑N/A
DYes❑NoON/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc.)?
48. -Does the File Contain Penalty Assessment Notices?
l7YespNo®N/A
❑YespNopN/A
pYes❑NopN/A
49. Does The File Contain Proof Of Penalty Collection?
❑YespNo®N)A
❑YesONoON/A
❑YespNopN/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.OYesONo®N/A
a.OYesONoON/A
a.OYesONoON/A
b. Is SIU in Compliance with Order?
b.OYesONo®N/A
b.OYesONoON/A
b.OYesONoON/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes M No
❑Yes ❑ No
❑Yes ❑ 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 SIU.
Dichlorobromomethane has been a recurring contaminant. The facility is actively working to eliminate this compound. The
concentrations have significantly been reduced.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MMND/YY
I I I I I I I I I I I I I I
I. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:
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:
OVERALL SUMMARY AND COMMENTS:
Comments: A very well -run program.
Requirements:
Recommendations:
NOD: ❑ YES M NO
NOV: ❑ YES ONO
QNCR: ❑ YES M NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 12/23/2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3