NC0028916_Pretreatment Audit_20140206

ACM
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
February 6, 2014
Joe Shields
Pretreatment Coordinator
Town of Troy
444 North Main Street
Troy, North Carolina 27371
SUBJECT: Pretreatment Audit Inspection Report
Town of Troy WWTP
NPDES Permit No. NC0028916
Montgomery County
Dear Mr. Shields,
Enclosed you will find a copy of the Pretreatment Audit Inspection Report for the
inspection that Monti Hassan (PERCS Unit) and I performed at the Town of Troy wastewater
treatment plant on January 24, 2014. Also, an industry site inspection was performed by the
POTW at Wright Foods (IUP# 0003) with John Michel (VP of Operations) and Jeff Nance
(Project/Process Engineer). Please see the recommendations and requirement sections on pages
eight and nine of the Pretreatment Audit Report. The report indicates that Troy WWTP
continues to meet the pretreatment requirements as outlined in 15A NCAC 2H .0904 (b) for
Modified Pretreatment Programs. You are commended for your continued success in
maintaining your program. If you have any questions, please contact me at [phone].
Sincerely,
Dale Lopez
Environmental Specialist
Enclosures: Pretreatment Audit Inspection Report
EPA Water Compliance Tnspection Report
225 Green Street — Suite 714 — Fayetteville, North Carolina 28301-5095
Phone: [phone] FAX: [phone] Customer Service 1-877-623-6748
Internet:: www.ncwatercivalitv.orq
An Equal Opportunity'Affirmative Action Employer

Mr. Shields
February 6, 2014
Page 2 of 2
cc:
Comprehensive Guidance for NC Pretreatment Programs, Chapter 7, Section D, Page 3
Comprehensive Guidance for NC Pretreatment Programs, Chapter 8, Append. 8-B
Ten_pages of PTfiling system improvement ideas
FRO PT Files (Dale Lopez) _

United States Environmental Protection Agency
E n/� Washington, D.C. 20460
f Water CompIianre Inspention Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 I N I 2 15I 3I NC0028916 111 121 14/01/24 117
Type Inspector Fac Type
18I r,I 19I S I 20II
IIIIIII66
Remarks
211IIIL111IIIIIIIIIIIIIIII1111IIIIIIIIIIII
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA----------Reserved
671 3.0 169 70I 3 I 711 I 721N I 731 1 174 75I 1 I I 1 1 1 180
L
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Troy WWTP
650 Glen Rd
Troy NC 27371
Entry Time/Date
10:30 AM 14/01/24
Permit Effective Date
10/01/01
Exit Time/Date
03:00 PM 14/01/24
'Permit Expiration Date
14/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joseph Edward Shields/ORC/910-572-3661/ -
Other Facility Data
-
Name, Address of Responsible OfficialfTitle/Phone and Fax Number
Contacted
Benny Ray Dennis,444 N Main St Troy NC 27371//910-572-7841/9105723663 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name d Signature(s) of Inspector( Agency/Office/Phone and Fax
Dale Lopez FRO WQ//910-433-3300 Ext.712/
$49.-'‘
Numbers Date
r
' 610 Y-
Signature o Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NC0028916
14/01/24 117 18IGI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This Pretreatment Audit Inspection Report concerns the inspection of pretreatment records and files that
Monti Hassan (PERCS Unit) and I conducted on January 24, 2014 at the Town of Troy wastewater
treatment plant. Also, an industry site inspection was performed by the POTW at Wright Foods (IUP# 0003)
with John Michel (VP of Operations) and Jeff Nance (Project/Process Engineer). Please see the
recommendations and requirement sections listed below. The report indicates that Troy WWTP continues
to meet the pretreatment requirements as outlined in 15A NCAC 2H .0904 (b) for Modified .Pretreatment
Programs. You are commended for your continued success in maintaining your program.
Recommendations:
1. Please continue to follow the frequency of sampling noted on the IUP limits page.
2. Please continue to follow the ERP concerning limit violations and the required enforcement letter from
the POTW.
3: Please consider revising the format of the enforcement letter. Please see the enclosed example of an
Notice of Violation letter (Comprehensive Guidance for North Carolina Pretreatment Programs, Chapter 8,
Appendix 8-B, Page 1).
4. Please consider modification of the IUP: possibly changing from a Daily Maximum limit to a Monthly
Average limit.
5. Please consider performing the SIU sampling events early in the month in order that the Monthly
Average values may be evaluated, instead of a Daily Maximum limit (as is presently reviewed).
6. Please speak with or email Monti Hassan (PERCS Unit) concerning possibility that there is available
allocation for increasing the IUP permit limits or certain limited parameters.
7. In preparation for the 2013 PAR, please review the PERCS website for PAR Guidance:
http://portal.ncdenr.org/web/wq/swp/ps/pret/parguide
8. Please see the attachments to this report as a source of ideas for improvement for your PT files.
Requirements:
1. Since Wright Foods was in Chronic SNC for pH and for BOD during the second half of 2013, please
take appropriate actions. Please publish Public Notice; please write about the events and the violations
that caused the SNCs, and about the Public Notice in the Narrative of the 2013 PAR; please submit
publication and the Affidavit with the 2013 PAR; and please note SNC on the 2013 PAR SNCR form.
Page # 2

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NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT AUDIT REPORT
Background Information. [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Troy
2. Control Authority Representative(s): Joe Shields
3. Title(s): Pretreatment Coordinator/Director POTW
4. Address of POTW:
Mailing 315 North Main Street
City Troy, NC
Zip Code 27371-3661
Phone Number [phone] Fax Number [phone] E-Mail troywwtp650Ayahoo.com
5. Audit Date 01/24/2014
6. Last Inspection Date: 07/30/2013 Inspection Type:® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ['Yes ❑ No ® NA
Parameters Covered Under Order
PCS (WENDB)Coding
Trans.Code Main Program Permit Number MM/DD/YY , Inspec.Type . Inspector Fac. Type
LNJ INIC10 10 12 18 19 11 16 1 l01 l24I14I IGI IS - I l l
(DTIA) (TYPI) (1NSP) (FACC)
10. Current Number of Significant Industrial Users (SIDS)?
11. Current Number of Categorical Industrial Users (CIUS)?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIIJs Not Sampled by POTW in Last Calendar Year?
14. Enter Higher Number of 12 or 13
1
0
0
0
0
SIUS
CIUS
NOIN
15. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
16. Number of SIUs with No IUP, or with an Expired IUP
Please see #7 of File Review Comments
17. Number of Sills in SNC for Reporting During Either of Last 2 Semi -Annual Periods
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
Semi -Annual Periods
1
1
0
0
0
PSNC
NOCM
MSNC
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
0
SNIN
North Carolina Pretreatment Audit Form
Paae 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Orogram
Element in their File, with all supporting documents and 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)
12/30/2008
Yes ❑ No
02/18/2009
/1 Yes ❑ No
01/31/2014
Industrial Waste Survey (IWS)
12/21/2009
Yes ❑ No
12/23/2009
❑ Yes ►1 No
12/31/2014
Sewer Use Ordinance (SUO)
12/28/2012
.. Yes ❑ No
01/03/2013
1 Yes ❑ No
Enforcement Response Plan (ERP)
12/08/2009
/1 Yes ❑ No
12/21/2009
I1 Yes ❑ No
Long Term Monitoring Plan
(LTMP/STMP)
12/08/2009
►/ Yes ❑ No
12/21/2009
II1 Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
® Yes ❑ No If yes, Please list these towns and/or areas.
Mandy Sanitary District
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 12/07/2012
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ❑ Yes ® No
If no, POTW must send copy within 30 days.
The PT Coordinator agreed to hand carry a copy of the ERP to the SIU
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
3
). Please Rate the Following: S=Satisfactory
M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
CIS ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
►1S ❑M ❑U
Access to Operable Sampling
Equipment
'IS ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
►IS ❑M ❑U
Reference Materials
►S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S ❑M ❑U
Computer Equipment (Hardware and
Software)
►1S ❑M ❑U
North Carolina Pretreatment Audit Form
Pao'

31..Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
Computer Excel spreadsheets
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges & Laboratory costs
Public Perception/ Participation
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
During 2013, Wright Foods was added, and Capel was dropped as an SIU
34. Has anyone from the public ever requested to review pretreatment program files? ❑ Yes.// No
If yes, Explain procedure. Ifni), How would the request be addressed?
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed?.
As Needed
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ❑ Yes.® No
38. Were all industries in SNC published in the last notice? ❑ Yes ® No
Permitting (Industrial Waste Survey-IWS)
39a...How does the POTW become aware of new or changed Users?
The POTW is informed by the Town officials
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the.
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?)
By asking the industry to answer an lIWS form
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there?
One
Please list each site and how it is permitted, if applicable.
IUwharie Environmental (permitted as a local IU
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example.
manifests required)
43. - How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, What parameters are over allocated?
45. If yes to #43, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/AI
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Pump & Haul
designated point
Pollutants specified or that will affect the plant adversely.
samples drawn,
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
The level of the pollutant , and the LTMP & STMP
North Carolina Pretreatment Audit Form
Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. 1Monthly Surcharges
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
The potential for the SIU to affect the POTW*
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Wright Foods does need an SSCP
56. How does the POTW decide where the sample point for an SIU should be located?
At an effluent point where there is process waste only
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ❑ Yes ❑ No If yes, Explain.
58. Who performs sample analysis for the POTW for
The POTW takes all of the samples
Metals Meritech
Conventional Parameters Meritech
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
The POTW collects all samples for the SIU and completes the Chain of Custody forms
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is L/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all L/STMP Monitoring? ® YES ❑ NO
60c. Is L/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP effluent data reported on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to L/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, Who completes your HWA? Phone ( )
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, What is the reason for the revision? (mark all that apply) ['Increased average flow ❑NPDES limits change
['More LTMP data available ['Resolve over allocation ❑5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ® Pass Through ['Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain.
Summary
The engineer is planning to upgrade
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
North Carolina Pretreatment Audit Form
PA OP. 4
No

• INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU
INSPECTION)
J66. User Name
Wright Foods
67. IUP Number
0003
68. Does File Contain Current Permit?
/1 Yes ❑ No
effective 08/15/2013
69. Permit Expiration Date
08/01/2018
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
// Yes ❑ No
07/19/2013
72. Does File Contain Inspection Completed Within Last Calendar Year?
❑ Yes 0 No
01/25/2014
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ■Yes LNo
b. ►SYes •No
A Spill Control Plan is in
progress of being written
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No®N/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. LYes ■No 09/12/2013
b.®Yes :No ❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
►1 Yes ❑ No
Except missed Cu & Zn for
Sept2013
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
►1 Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its Sampling
as Required by IUP, including Flow?
❑Yes❑No®N/A
Flow is measured from the
potable water meter
79. During Most Recent Semi -Annual. Period, Did SIU submit all reports on
time?
❑YesDNo N/A
80a. For categorical IUs with Combined Wastestream Forinula (CWF), does file
"include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
80b. For categorical lUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All Limits
/1 Yes ❑ No
Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
►1 Yes ❑ No
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring
Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
c. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU Limit violations in the POTW's sampling of SIU?
a.❑Yes ❑No0N/A
b.❑Yes❑NooN/A
c.❑Yes ❑No®N/A
The POTW samples the SIU every
month, as according to the IUP
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
►1 Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP?
®Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes®No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes II No
North Carolina Pretreatment Audit Form
Page 5

FILE REVIEW COMMENTS:
1.. The following are industries that have local permits:
o North Carolina Southern Correctional
o North Carolina Correctional
o Montgomery School
• Uwharrie Landfill
o International Automotive Components (IAC), formerly Collins and Aikman
Capel, Inc.
2. Wright Foods IUP was effective on 08/01/2014.
3. Wright Foods' flow is measured from the monthly potable water meter.
4. In Wright Food's pretreatment site inspection report, the PT Coordinator requested that Wright Foods should have a
Slug Control Plan.
5. The following are Wright Foods IUP parameter limits:
Parameter
Daily Maximum
Frequency
Type
Industry
POTW
Flow
0.125 (MGD)
Every sample
Meter
Yes
Yes
BOD
600 mg/L
Monthly
Composite
No
Yes
TSS
300 mg/L
Monthly
Composite
No
Yes
pH
6 to 9 pH units
Every sample
Grab
No
Yes
Copper
0.3 mg/L
Monthly
Composite
No
Yes
Zinc
0.8 mg/L
Monthly
Composite
No
Yes
6. Wright Foods parameter test results (* denotes an IUP limit violation):
Date
Flow (gallons
per day)
pH (pH units)
BOD (mg/L)
TSS (mg/L)
Copper (mg/L)
Zinc (mg/L)
12/27/2013
56,900
10.5 *
187
167
0.17
0.28
11/20/2013
68,000
9.6 *
750 *
333 *
0.067
0.158
10/22/2013
54,000
5.4 *
>5260 (the SIU was not
in production on this day)
55
0.037
0.082
09/25/2013
78,000
Oversight,
None tested
770 *
126
Oversight,
None tested
Oversight
None tested
7. As a result of the above listed parameter results, pH and BOD are in Chronic SNC for the second half of 2013:
a. 100% pH violations (please note that according to the Comprehensive Guidance for North Carolina Pretreatment Programs,
Chapter 7, Section D, page 3: "SNC for chronic violations is determined for all limited parameters, including pH", please see
the page enclosed with this report).
b. 66% BOD violations.
8. Wright Foods was not in TRC SNC violation for pH and BOD.
9. During September 2013 (the first month after the effective date of the IUP), because of an oversight by the PT Coordinator, the
pH, Copper, and Zinc were not collected for analyzes. However, BOD & TSS were sampled during September, and each of the
parameters were sampled as according to the IUP for the remaining three months of the calendar year. Since the number of
sampling events amounted to more than the very minimum State requirements for sampling (twice per year by the POTW and
twice per year by the SIU --- of which the POTW may perform in lieu of the SIU performing the sampling), an enforcement from
the State to the POTW was not regarded as prudent under these circumstances. In the future, please follow the IUP sampling
frequency.
North Carolina Pretreatment Audit Form
Pane 6

INDUSTRY INSPECTION PCS CODING:
Trans.Code
INI
Main Program Permit Number
INICIO Io 1218 19 11 16 I
MM/DD/YY Inspec:Type Inspector Fac. Type
101 I /4 1 14 1 . I IJ l I's I 12 I
(DTIA) (TYPI) (INSP) (FACC)
.1. Industry Inspected: Wright Foods
2. Industry Address: 1 Wright Way, Troy, NC 27371
3. Type of Industry/Product: A food processor that .processes solely apple sauce (with the potential of processing other fruit
products)
4. Industry Contact: John Michel Title: VP of Operations Phone: [phone] Fax: [phone]
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:
Wright Foods in Troy processes only apple sauce. The DAF unit was in the process of evaluation for use in pretreatment of
wastewater. It appeared to me that there was a, possible need for more spill containment under large containers of reagent, especially
those that were transferred by forklift.
North Carolina Pretreatment Audit Form
Page 7

Audit SUMMARY AND COMMENTS:
Audit Comments: The files appear to be in good order.
Recommendations:
1. Please continue to follow the frequency of sampling noted on the IUP limits page.
2. Please continue to follow the ERP concerning limit violations, as well as sending the required enforcement letter from the POTW.
3. Please consider revising the format of the enforcement letter. Please see the enclosed example of a Notice of Violation letter
(Comprehensive Guidance for North Carolina Pretreatment Programs, Chapter 8, Appendix 8-B, Page 1).
4. Please consider modification of the IUP: possibly changing from a Daily Maximum limit to a Monthly Average limit.
5. If the IUP is modified to Monthly Average limits, please consider performing the SIU sampling events early in the month in order
that the Monthly Average values may be evaluated and retest sampling can be performed.
6. Please speak correspond with Monti Hassan (PERCS Unit) concerning possibility that there is available allocation for increasing
the IUP permit limits or certain limited parameters.
7. In preparation for the 2013 PAR, please review the PERCS website for PAR Guidance:
http://portal.ncdenr.org/web/wq/swp/ps/pret/parguide
8. Please see the attachments to this report as a source of ideas to improve your PT files.
Requirements:
1. Since Wright Foods was in Chronic SNC for pH and for BOD during the second half of 2013, please take appropriate actions. Please
publish Public Notice; write about the events and about the violations that caused the SNCs and about the Public Notice in the
Narrative of the 2013 PAR; please submit publication and the Affidavit with the 2013 PAR; and please note SNC on the 2013 PAR
SNCR form.
• As additional information concerning the 2013 PAR, the PPS form should include the number of enforcements for the PAR year.
However, not including those NOVs, NNCs, AO's, or similar that were assessed to SIUs and were sent in January for violations that
happened in December of the PAR year. (However, the number of Public Notices is the exception.) In the Narrative, if there were
NOVs, NNCs sent in January 2014, then please note the year overlap for the enforcement, so as to explain the discrepancy between
the PPS, IDSF, and the Narrative of the PAR.
North Carolina Pretreatment Audit Form
Page 8

NOD: ❑ Yes ® No
NOV: ❑ Yes . ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satis
arginal ❑ Unsatisfactory. ❑
Audit COMPLETED BY: Dale L i lO) and Monti Hassan (PERCS Unit) DATE: 02/06/2014
Reviewed by:4DATE:
'7 1
North Carolina Pretreatment Audit Form
PaoP 9

•
1,1,0
Section
Chapter 7
C pll d spectle
ompliance Judzement Discussion
SNC•IMERMINATION - LIMITS VIOLATIONS
11
Calculation sheets to aid calculating SNC with Limits are found in Appendix 7-00 If •
there are no vi .4stionkthere oto) n to determine SNC with Limits. SNC
violations fall into 3 categories:
T
Chronic,
e echnical Review
o
ose causJg pass- nce, or e siment.
,
Violations of any gnitude are evalua determiiing if viol,. worts are Chronic SNC.
However, violations must exc the limit by one of two factors before being considered
MC violations.
1. •Preliminary Calculatigns:
A. Units conversion4: If the I Is in the SIU per are in units other than
concentration, the t-ikTW must first convert the sample results to the units of
the permit limits. Typically, other units may be mass (lbsiday) or production
(IbS pollutin/1b si uct).
Averages: If the Sin XUP includes a Monthly Average Limit or other type sf
average limit, calculate averages of all the monitoring results for each
parameter for the -appropriate. time period, If there is 'Fitly one sample in the
average period, that value should be used as the average. Also s: p 101 of
EPA's Industrial User Inspecgion and Sampling Manual For POTWs. April
C Compliance jug ent Points (C.IPslz To calculate SNC for chronic Of TRC
s.
violations, the number of compliance judgement qrinns (CJPs) ust be
calcula.ted for each pa.rameter, CIPs are calculated for each parameter as
follows:
CIPs # individual V slues + #averages calculated.
•3. ;ChitinicSNC: Chrose7c SNC is &ten:lain:4 by calculating the
•
are violations for each parameter using the followmg
wo1os1-- tom' Luauimber- ,,,;:flcip'47.17:111:
04. :v19440#25 % Ve4ffeheUNC forcvithtos
,-pf CDs ghat •
Chapter: SAMPLING. COMPLIANCE. AND INSPECI1ON
Mew= COMP:OX '3LIDG(D)
flevidon Dam: Au I. 1994
Cheper '7
Seitiva D „
Page 3 .

Chapter .8
Efforcement Guidance
Appendix 8-B. Example Notice of Violation
an) of Olctropcti5
July 13, 1993
Mr. John Doe
Environmental Manager
JRP Industries
5266 Chatsworth
Metropolis, NC 27519
Subject: NOTICE OF VIOLATION
JRP Industries
Pretreatment Permit #0003
Dear Mr. Doe:
.JRP Industries has been found to be
Discharge Permit (#0003) issued by
summarized as follows:
REGISTERED MAIL •
RETURN RECEIPT REQUESTED •
in violation of Part I.. B of their Wastewater
the City of Metropolis. The violations are
Date
sMonitoring
i
. Parameter
Daily
Limit
}CriterionCriterion
f
Technical
F•
Result
Technical
i Review
Exceeded
March 20
pelf
Lead
1
No
March 30 .
City
Lead
1
Yes
lea 20
Self
Lead
.1
Yes
These violations place JRP Industries in Significant Non -Compliance for the January t
June Semi -Annual period.
In accordance with the City's Enforcement Response Plan, the City of Metropolis
Industrial Waste Section hereby assesses JRP Industries a $100 penalty. Payment of the
penalty and a report contalnan the pPobabie4use of the violations-rld plans to re
corcaplaance must be subriaitted to this ffdce within 30 days of P egpt pf thas:notice.
If JRP Industries fails to return to compliance, then additional actions, including increased
penalties or issuance of an enforceable order, will becompleted in accordance with the
City's Enforcement Response Plan. Please be aware that the City's Sewer Use Ordinance
gives the Director the authority to assess penalties of up to $ 10,000 per day per violation.
The appeal of civil penalties is provided for in section 4.2(h) (NC model section) of the
City's Sewer Use Ordinance. If you wish to appeal this penalty assessment, written
demand identifying the specific issues to be contested must be made to the Director within
30 days of the receipt of this letter. Unless such demand is made, this decision shall be
final and binding. Please contact the Industrial Taste Section if you have any questions.
Sincerely,
sma
Jane Smith
Pretreatment Coordinator
Chapter: Enforcement Guidance
Filename: Model POTWNOV
Revision Date: August 12, 1993
Chapter 8
Appendix 8-B
Page 1

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Semti-Annuai Data Report
Wastewater Permit'#
ip4cvv, a.
K
Permit Limits
Maximum
DL mg/I
Parameter
Daily max
Monthly Max
Date Collected
3-Aug
31-Aug
16-0ct
6-Nov
Flow, mgd .
0.01
0.000
pH, s.u.
6-11.6
6.69
6.76
6.61
6.61
6.8
TEMPERATURE, ° C
25.0
30.2
14.2
16.0
30.2
RODS (mg/I) QUARTERLY
900
600
160•
160.0
2
COD (mg/I) QUARTERLY
3000
2500
203
203
16
TSS (mg/I) QUARTERLY
1500
1000
770
770
2
OIL AND GREASE (mg/I)QUARTERLY
140
100
<
5
6
6
CADMIUM (mg/I) MONTHLY
0.11
0.07
<
0.002
<
0.002
<
. 0.002
. 0.002
CHROMIUM (mg/I) MONTHLY
COPPER
2.77
1.71
0.154
0,006
(mgll) MONTHLY0.154
3.38
2.07
1.170
0.266
1.170
0.002
CYANIDE (mg/I) MONTHLY
1.19
0.66
0.006
0.005
LEAD (mg/I) MONTHLY
NICKEL
0.69
0.43
0.096
0.016
0.010
(mg/I) MONTHLY
..3.98
2.00 .
2.380
1.740
0.333
0.108
2.380
0.010
SILVER (mg/I) MONTHLY
0 43
0.24
<
0.005
<
0.005
0.005
ZINC (mg/I) MONTHLY
. 2.61
1.48
0.062
0.062
0.010
IRON (mg/I) BIANNUALLY
report and monitor
only
11.100
11.100
0.026
MOLYBDENUM(mg/I) BIANNUALLY
report and monitor only
<
0.005
<
0.006
0.005
ALUMINUM (mg/I) BIANNUALLY
report and monitor only
16.10
16.100
0.060
AMMONIA (mg/q BIANNUALLY
report and monitor only •
<
0.60
<
0.50
0.100
ARSENIC (mg/I) BIANNUALLY
report and monitor only
<
0.010
<
0
0.010
SELENIUM (mg/I) BIANNUALLY
report and monitor only
c
0.010
<
0
0.010
TKN (mg/I) BIANNUALLY
NITRATE -NITRITE, N
report and monitor only
0.66
0.66
0.20
(mg/1) BIANNUALLY
TOTAL PHOSPHORUS
report and monitor only
8.49
8.49
(mg/I) BIANNUALLY
report and monitor only
2.040
2.04
0.10
0.020
CHLORIDE (mg/I) BIANNUALLY
report and monitor only
6.23
6.23
0.1
MERCURY 1631 (ng/l) ANNUALLY
report and monitor
only
1.00
TTO (mg/I) BIANNUALLY
2.13
0.01
BDL = Below Detection Limit (DL)
NA = Not Applicable.
" = QA/QC did not meet
•
all specifications but the data is
believed to be correct.

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