NC0026441_Pretreatment Compliance Inspection_20200922

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Chris McCorquodale
Director of Public Works & Utilities
Town of Siler City
PO Box 769
Siler City, NC 27344
NORTH CAROLINA
Environmental Quality
September 22, 2020
Subject: Pretreatment Compliance Inspection
Town of Siler City
NPDES Permit No. NCO026441
Chatham County
Dear Mr. McCorquodale:
On August 24, 2020, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Inspection (PCI) of Town of Siler City's pretreatment program. The assistance given by
Ms. Brittany York, Wastewater Superintendent, and you, was greatly appreciated. The inspection report
is attached. Findings during the inspection were as follows:
1. The Town has two Significant Industrial Users (SIUs) discharging to the POTW, neither is a
Categorical Industrial User (CIU). It was noted that the two SIUs were not in Significant Non -
Compliance (SNC) for the last two semi-annual periods.
2. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and detection limits since last inspection.
A review of the files containing the pretreatment program elements was conducted. All files
were up to date. Update of Headworks Analysis (HWA) was due September 1, 2020. It was
noted that LTMP data from 2019 and 2020 were not used in the HWA update at the time of
inspection. Please contact DWR Central Office Pretreatment staff about whether the data should
be included in the HWA.
4. The Industrial User Pretreatment Permit (IUP) file review included Brookwood Farms, Inc.
(Permit No. 003) and Mountaire Farms (Permit No. 004). All files were available for review.
During the most recent semi-annual period, the POTW identified one monitoring violation by
Mountaire Farm for failure to sample and analyze BOD. The POTW issued a Notices of
Violation to address the violation as required by the Enforcement Response Plan.
norDE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
r rnani wa Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
oep,m ,t ie n��menni"i;� 919.791.4200

Thank you for your continued support of the Pretreatment Program. If you have questions regarding to
the attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or email:
Cheng. zhang@ncdenr. gov).
Sincerely,
laDOCUSigned by:
41�w
BCDA9D825D4A46D...
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Siler City PCI Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO

` NORTH 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)I
1. Control Authority (POTW) Name: Town of Siler City
2. Control Authority Representative(s): Chris McCorguodale, Brittany York
3. Title(s): Director of Public Works & Utilities, Wastewater Superintendent
4. Last Inspection Date: December 14, 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
ICIS CODING
Main Program Permit Number
I N I C 1 0 10 12161414111
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
1 08 1 241 20
7. Current Number Of Significant Industrial Users (SIUs)?
2
8. Number of SIUs With No IUP, or With an Expired IUP?
I 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)?
0
16. Number of CIUs in SNC?
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 SIUs in SNC) Not Pu
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?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES [I NO
Multiple violations for cadmium,
BOD, ammonia, TSS, and fecal
❑ 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. If NO 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
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
2/8/2016
® Yes ❑ No
5/6/2016
® Yes ❑ No
9/1/2020
Industrial Waste Survey (IWS)
5/4/2018
® Yes ❑ No
5/15/2018
® Yes ❑ No
2/28/2023
Sewer Use Ordinance (SUO)
12/18/2012
® Yes ❑ No
1/2/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
6/2/2020
® Yes ❑ No
11/19/2008
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/25/2016
® Yes ❑ No
5/6/2016
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Brookwood Farms
2. Mountaire Farms
3.
30. IUP Number
003
004
31. Does File Contain Current Permit?
®Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
12/31/2020
12/31/2020
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
F a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/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
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
®Ycs ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® 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
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❑FN/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes0No[0
❑Yes❑NoON/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoON/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
❑Yes❑NoON/A
❑Yes❑NoON/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoON/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
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No[O
®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
49. Does The File Contain Proof Of Penalty Collection?
❑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
11
b. Is SIU in Compliance with Order?
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
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
41— Moutaire Farms missed BOD in its sampling on June 30, 2020.
47 - The POTW issued a NOV for Mountaire's monitoring violation.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed.
Requirements: None
Recommendations: Contact DWR Central Office about whether LTMP data from 2019 and 2020 should be included in HWA
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 24, 2020
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3