NC0028916_Pretreatment Inspection_20130830

Pat McCrory
Governor
A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Thomas A. Reeder John E. Skvarla, III
Director Secretary
August 30, 2013
Joe Shields
Pretreatment Coordinator
Town of Troy
444 North Main Street
Troy, North Carolina 27371
SUBJECT: Pretreatment Compliance Inspection Report
Town of Troy WWTP
NPDES Permit No. NC0028916
Montgomery County
Dear Mr. Shields,
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the
inspection of pretreatment records and files that was conducted -on July 30, 2013 at. the Town of
Troy wastewater treatment plant. Also, an industry site inspection was performed by the POTW
at Capel (IUP# 0002) with David Wright (Capel Dye House Manager). 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].
Enclosures:
cc:
Dale Lopez .
Environmental Specialist
Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
.FRO PT F les (_Dale :Lopez).]
225 Green Street — Suite 714 — Fayetteville, North Carolina 28301-5095
Phone: [phone] FAX: [phone] \ Customer Service 1-877-623-6748
Internet:: www.ncwaterquality.orq
An Equal Opportunity\Affirmative Acton Employer

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection ReportApproval
Form Approved.
OMB No. 2040-0057
expires 8-31-98
Section A: National Data System. Coding=(i.e., PCS)
Transaction Code NPDES yr/mInspectio
1 I N I 2 15 I 31 NC0028916 111 121 13/07/30.:. 117;
no/day.. Type Inspector FacType
"IN- I. 19I S I. 201 II
I I I I -1 I I I I I I I 1 I I I66
Remarks
21I I I I I I I I I I I I I I I I I I I I I I I I 11' 11 .I I 4
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 • .t .QA • -------- ----------=---Rserved-
67 I 2.0 169 70 13 I 711 I 72 I N I 731I, ' 174 75I ' I . • I '1 1 1 I 180
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
11:00 AM 1.3/07/30
Permit Effective Date
10/01/01
Exit Time/Date
02:00 PM 13/07/30
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 Official/Title/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(s) d Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dale Lopez FRO WQ//910-433-3300 Ext.712/
Signature o Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
9/3/ 3
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
31 NC0028916 1
11 121 13/07/30 117 181P1
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the inspection of
pretreatment records and files that was conducted on July 30, 2013 atthe Town of Troy wastewater
treatment plant. Also, an industry site inspection was performed by the POTW at Capel (IUP# 0002) with
David Wright (Capel Dye House Manager). 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]
FILE REVIEW COMMENTS:
1 Although the IUP did not require the Slug Control plan, the Pretreatment file contained one.
2. The following were the industries that had local permits.
• North Carolina Southern Correctional,
• North Carolina Correctional,
• Montgomery School
• Uwharrie Landfill
• International Automotive Components (IAC), formerly Collins and Aikma.
• Handi Sanitary District
3. On July 1, 2012, Joe Shields became the pretreatment coordinator for the Town of Troy.
4. Wright Foods, a large food processing industry, was in the process of completing the Industrial User
Wastewater Survey and Permit Application. The Pretreatment Coordinator planned to submit it to PERCS
soon. It appeared that Wright Foods would be an SIU with the Troy Pretreatment Program.
Page # 2

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Troy
2. Control Authority Representative(s): Joe Shields
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 05/07/12 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: Are Milestone Dates Being Met? ❑ YES ❑ NO
PCS CODING
Trans.Code
NI
Main Program Permit Number
MM/DD/YY
1 N.1 C 1 0 1 0 1218 1 9 1 1 16 1 1 071 30 1131
Inspec.Type Inspector Fac. Type
1 P 1 1 SI 1 1 1
TIA) (TYPI) (INSP) (FACC
7. Current Number Of Significant Industrial Users (S1Us)?
1
SIUS
8. Current Number Of Categorical Industrial Users (CIUs)?
0
CIUS
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. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
0
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Put
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 S. NO
❑ YES EI NO
Limits:
Reporting:
lished:
0
0
0
0
❑ YES .0 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? Z YES
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
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES Z NO
If yes, which ones? Eliminated: Added:
❑ NO
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 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 Pro rag m 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
0 Yes ❑ No
12/23/2009
/1 Yes ❑ No
12/31/2014
Sewer Use Ordinance (SUO)
12/28/2012
N Yes ❑ No
01/03/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
12/08/2009
4 Yes ❑ No
12/21/2009
►ZI Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/08/2009
►1 Yes ❑ No
12/21/2009
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name .
1. Capel, Inc.
2.
3. •
30. IUP Number
0002
31. Does File Contain Current Permit?
►Z/ Yes
03/18/09
Mod. Effective
09/09/10
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
01/10/2014
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
I Yes ❑ No
01/02/2009
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I Yes ❑ No
05/17/2012
❑ Yes ❑ No
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►-Yes the
IUP does not
require the plan
a. •Yes •No
b. ■Yes ■ No
a. ■Yes ■No
b. •Yes ■ No
Please see File Review Comment #1
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. - Yes ■No
03/30/2009
b.®Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
a. ■Yes ■No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/Z1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ .No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
❑Yes❑No❑N,/A
❑Yes❑No❑N/A
on time? The POTW collects all the SIU samples, and the POTW
receives the reports from the commercial lab
42a. For categorical lUs with Combined. Wastestreatn Formula (CWF), does
file include process/dilution flows as Required by 1UP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or tows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
►1. Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
ElYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
None this year
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
c.❑Yes❑No®NIA
a.❑Yes❑No❑N/A
b.❑Yes ❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes ❑No❑N/A
c.❑Yes❑No❑N/A
Monitoring Violations? The POTW collects all the SIU samples, and the
POTW receives the reports from the commercial lab
Days?
aware
b. Did Industry Resample and submit results to POTW Within 30
c. If applicable, Did POTW resample within 30 days of becoming
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 I/ No
❑ Yes ❑ No
❑ Yes ❑ No
47. During the Most Recent Semi -Annual Period,' Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
NC DWQ Pretreatment Compliance Inspection (PCI) Form t.ipdated 7/25/07 Page 2

48. Does the File Contain Penalty Assessment Notices?
49. Does The File Contain Proof Of Penalty Collection?
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
• ❑ Yes ❑No®N/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
_❑ Yes ❑No®N/A
❑ Yes ❑No❑N/A.
❑Yes❑No❑N/A
a.❑Yes ❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes ❑No❑N/A
b.❑Yes ❑No❑N/A
a.❑Yes ❑No❑N/A
b.❑Yes ❑No❑N/A _
❑_ Yes Al No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
1. Although the IUP did not require the Slug Control plan, the Pretreatment file contained one.
2. The following were the industries that had local permits.
• North Carolina Southern Correctional, ,
• North Carolina Correctional,
• Montgomery School
• Uwharrie Landfill
• International Automotive Components (IAC), formerly Collins and Aikma.
• Handi Sanitary District
3. As of July 1, 2012, Joe Shields became the pretreatment coordinator for the Town of Troy.
4. Wright Foods, a large food processing industry, was in the process of completing the Industrial User Wastewater Survey
and Permit Application. The Pretreatment Coordinator • planned to submit it to PERCS soon. It appeared that Wright
Foods would be an SIU with the Troy Pretreatment Program.
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
I_ IN C I 01012181 911161 J07I30I131 f I f J S 1 J 2 1.
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Capel, Inc.
2. Industry Address: P.O. Box 826, 831 North Main Street, Troy, NC 27371
3. Type of Industry/Product: Textile
4. Industry Contact: David Wright Title: Dye House Manager
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:
OVERALL SUMMARY AND COMMENTS:
Comments: You are commended for your continued success in maintaining you program.
Requirements: None
Recommendations:
NOD: ❑ YES X❑ NO
NOV: ❑ YES El NO
QNCR: ❑ YES El NO
POTW Rating:
Satisfactory Ma ti j UnSatisfactory
PCI COMPLETED BY: Dale Lopez �� ' DATE: 08/30/2013
PCI Reviewed by: Belinda Henson i4Q-Gt ; - • Date: 9/3 /I 3
NC DWQ Pretreatment Compliance Inspection (PCI) Form updated 7/25/07 Page 4