NC0037508_PAR Narrative Updated_20200414

Public Works
'Water PoCCution ControCPCant
1094 Addor Road
Aberdeen, NC 28315
40" o£MaoAF
County of .Moore
PRETREATMENT ANNUAL REPORT (PAR)
MOORE COUNTY (NPDES # NC0037508)
[phone]- Phone
[phone]- Fax
February 27, 2020
NARRATIVE FOR EACH SIGNIFICANT INDUSTRIAL USER (SIU), 2018
GENERAL PROGRAM INFORMATION
• Permits are up to date.
• Connie Flowers completed the Pretreatment Compliance Inspection on February
28, 2019 with Jonathan Watts of the Fayetteville Regional Office. Thermal Metal's
annual inspection was completed as part of the Compliance Inspection.
• The SUO was updated to include Non -Significant Categorical Industrial Users and
submitted to the PERCS Unit for review on July 24, 2019 with the attorney's
statement being submitted on August 14, 2019. The updated SUO was approved by
the Moore County Board of Commissioners on August 20, 2019 and the adoption
documentation was sent to the PERCS Unit on August 21, 2019. The POTW
received an approval letter on August 23, 2019.
• The LTMP was updated as requested by PERCS. The updated LTMP was
submitted to the PERCS Unit on August 29, 2019 and an approval letter was
received by the POTW on December 17, 2019.
• The HWA was completed and submitted to the PERCS Unit on September 17,
2019. An approval letter was received by the POTW on December 17, 2019. Over
allocation of silver remains; however, the POTW silver effluent was <0.0005 mg/L
for 2019. The POTW plans to modify current silver limits in the IUPs and analyze
silver at the lowest available detection level to obtain a site -specific removal rate as
well as uncontrollable concentration to assist with the over allocation.
• The ERP was revised to include enforcement actions for dental dischargers. The
revised ERP was submitted to the PERCS Unit on December 3, 2019 and an
approval letter was received by the POTW on February 5, 2020.
• The ERP dates on the Division's Database Program Info Sheet are incorrect due to
the revision.
• The Program Information Database Sheet was updated by striking through Janna
Nall's information as Superintendent. Janna Nall resigned in December of 2019
and the county is in the process of hiring a new Superintendent.
• On all four IDSFs, there are some places where there is only one data point for the
year or one for each six-month period. The reason being that the parameter is only
tested biannually or annually.
• In all cases where the tested result was BDL or less than (<), 1/2 the DL was used
when averaging results.

Public Works
'Water PoCCution ControCPCant
1094 Addor Road
Aberdeen, NC 28315
40" o£Mao
County of .Moore
SIU COMPLIANCE STATUS
IUP # A005: Erico Incorporated (40 CFR 433)
[phone]- Phone
[phone]- Fax
• The facility was inspected on October 2, 2019. The SIU received a rating of
"satisfactory". During the inspection, no significant changes were documented.
• The SAT continues to maintain a good working relationship with the POTW.
• Erico failed to complete the 4-day testing required July -December 2019. The NOV
wasn't issued until January 2020 and therefore isn't included on the Pretreatment
Performance Summary. The SIU completed the 4-day testing the week of January
6, 2020 and all results were below the required permit limits.
• Erico's current permit expires June 30, 2023.
IUP # A007: Pinnacle Furnishings, Inc. (40 CFR 433)
• The facility was inspected on November 12, 2019. The inspection was a final
inspection due to Pinnacle Furnishings, Inc. deciding to rescind their permit. The
rescindment was due to a drastic decline in production of anodizing. The POTW
rescindment letter was submitted to the PERCS Unit on December 17, 2019 and an
approval letter was received by the POTW on January 14, 2020.
• Due to permit rescindment, Pinnacle's IDSF has no data for the second 6 months.
• Pinnacle was issued the following 5 NOVs in 2019.
o January 2019 — self -monitoring violation:
Pinnacle failed to complete bi-annual self -monitoring required July -
December 2018. Pinnacle had no process discharge August 2018-December
2018; therefore, POTW declared the violation wasn't intentional and didn't
constitute SNC. The self -monitoring was completed January 2019.
o January 2019 — nickel violation of exceeding monthly average limit:
Pinnacle collected samples on January 3 1 " and reported a nickel value of
2.20 mg/L which exceeded the monthly average limit of 2.00 mg/L. Moore
County and Pinnacle collected samples on June 271h and reported nickel
values of 1.04 mg/L and 1.06 mg/L. The June nickel values reduced the
monthly average for the January -June Determination Period and prevented
SNC.

Public Works
'Water PoCCution ControCPCant
1094 Addor Road
Aberdeen, NC 28315
County of .Moore
IUP # A007: Pinnacle Furnishings, Inc. (40 CFR 433) cont'd....
[phone]- Phone
[phone]- Fax
o June 2019 — BOD violation of exceeding daily maximum limit and monthly
average limit:
Moore County and Pinnacle collected samples on June 27th and reported
BOD values of 930 mg/L and 928 mg/L which exceeded the daily
maximum limit of 900 mg/L. The monthly average was 929 mg/L which
exceeded the monthly limit of 500 mg/L.
o January -June 2019 — BOD SNC daily chronic violation and SNC monthly
average TRC violation:
The calculated percent of daily chronic violations was 66.7% which
exceeded the 66% requirement and resulted in SNC for daily chronic
violations.
The calculated percent of TRC violations was 50% which exceeded the
33% requirement and resulted in SNC for monthly average TRC violations.
o July 2019 — late reporting violation:
July flow report was required by August 30th; however, the POTW didn't
receive it until September 6th
• Public Notice of Pinnacle's SNC was published in The Pilot, a local newspaper, on
August 14, 2019.
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Public Works
'Water PoCCution ControCPCant
1094 Addor Road
Aberdeen, NC 28315
40" o£MaoAF
County of .Moore
IUP # A008: Thermal Metal Treating, Inc. (40 CFR 433)
[phone]- Phone
[phone]- Fax
• The facility was inspected on February 28, 2019. The SIU received a rating of
"satisfactory". During the inspection, no significant changes were documented.
• The SIU continues to maintain a good working relationship with the POTW.
• Thermal Metal was issued 1 NOV in 2019 for late reporting. The November flow
and results were required by December 31, 2019; however, the POTW didn't
receive them until January 1, 2020.
• Thermal Metal failed to submit the second bi-annual TTO Certification for July -
December 2019. The POTW informed Thermal Metal by certified letter on
January 6, 2020 and collected samples on February 13, 2020 for TTO analysis.
• Thermal Metal's current permit expires June 30, 2020. The permit application was
submitted to the POTW on December 20, 2019.
IUP # A010: Southeastern Tool & Die (40 CFR 433)
• The Industrial Waste Survey completed in August 2018 revealed Southeastern Tool
& Die possibly needed to be permitted. Facility was visited in November 2018 and
samples were collected in January 2019. Southeastern Tool & Die was determined
categorical due to the powder coating; therefore, they did need to be permitted.
Southeastern Tool & Die was permitted on November 7, 2019.
• The facility was inspected on December 2, 2019. The SIU received a rating of "un-
satisfactory" due to the following items.
o No containment of chemical storage.
o No labels on process or storage tanks.
o Building contained 31 barrels of hazardous waste -NC DEQ had issued them
an Immediate Action Notice of Violation. They were required to test the
barrels to determine disposal and perform a comprehensive assessment of
soil in four areas of concern around the building. On February 20, 2020, the
POTW received an email that all barrels of hazardous waste have been
disposed of properly.
o No flow meter installed/calibrated.
• Flow meter was installed on December 15, 2019 and the POTW inspected the
installation on December 16th. The meter was calibrated on December 20, 2019.
Since the meter wasn't calibrated until late December, the IDSF sheet doesn't
contain flow data. Facility sent the January 2020 flow report to the POTW on
February 3, 2020.
• The SIU was unresponsive until the permit was issued by the POTW showing up
unannounced at the facility. The SIU has since been cooperative.
• SIU sampled on December 31, 2019. During the sampling, samples were also
collected for a TTO analysis in order to certify in the future. The TTO results were
all Below Quantitation Limits.

Public Works
'Water PoCCution ControCPCant
1094 Addor Road
Aberdeen, NC 28315
40" pr Mao
County of .Moore
IUP # A010: Southeastern Tool & Die (40 CFR 433) cont'd....
[phone]- Phone
[phone]- Fax
• December 2019 results had 2 violations which resulted in SNC. The SNC is
included on the Pretreatment Performance Summary; however, the NOVs weren't
issued until 2020 and are therefore not included.
o BOD violation of exceeding monthly average limit:
BOD result was 739 mg/L which exceeded the monthly average limit of
500 mg/L.
o July -December 2019 — BOD SNC monthly average chronic violation and
monthly average TRC violation:
The calculated percent of monthly average chronic violations was 100%
which exceeded the 66% requirement and resulted in SNC for monthly
average chronic violations.
The calculated percent of TRC violations was 100% which exceeded the
33% requirement and resulted in SNC for monthly average TRC violations.
o Silver violation of exceeding monthly average limit:
Silver result was 0.010 mg/L which exceeded the permit monthly average
limit of 0.005 mg/L. When the SIU permit was issued, the POTW had
assigned more stringent silver limits to help with over allocation. This limit
is too stringent; therefore, the POTW plans to modify the SIU permit prior
to the first required bi-annual sampling.
o July -December 2019 — Silver SNC monthly average chronic violation and
monthly average TRC violation:
The calculated percent of monthly average chronic violations was 100%
which exceeded the 66% requirement and resulted in SNC for monthly
average chronic violations.
The calculated percent of TRC violations was 100% which exceeded the
33% requirement and resulted in SNC for monthly average TRC violations.
• Public Notice of Southeastern Tool and Die's SNC was published in The Pilot, a
local newspaper, on March 4, 2020.
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• Southeastern Tool & Die's current permit expires October 31, 2024.