NC0028916_Pretreatment Audit_20090724

A711.
NCDENR
North Carolina Department of Environment and Natural resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
July 24, 2009
Grey Walls
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. Walls:
Enclosed you will find a copy of the Pretreatment Compliance
Inspection Report for the inspection that was conducted on July 8, 2009
in which Monti Hassan (PERCS Unit), Paul Rawls (DWQ-FRO) and I
met with you and Linda Walls (Pretreatment Coordinator for the Town
of Troy). Please notice that in the Audit SUMMARY AND
COMMENTS section of the report there is a recommendation and three
requirements with due dates. 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,
klDale Lope21.3
Environmental Specialist
Enclosures: Pretreatment Audit Inspection Report
EPA Water Compliance Inspection Report
cc:. PERCS - Pretreatment Unit
:FRO
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
. Dee Freeman
Secretary
O'o.e .
orthCarol7.na
GZtuz wly

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection 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 NI 2 1 51 31 NC0028916 111 121 09/07/08 1 17
Type Inspector Fac Type
181 GI 191 SI 201 1
I 'II I .I I I I I I I I I I 1166
• Remarks
211 I I I I I I I I I I I I I I I I 1 I I I I I 'I I I I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------Reserved-------- --
671 3.0 1 69 701 31 71 11 721 N 1 731 1 1 74 75I 1 1 1 1 I 1 180
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
10:00 AM 09/07/08
Permit Effective Date
04/08/01
Exit Time/Date
03:00 PM 09/07/08
Permit Expiration Date
09/06/30
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
E. Gray Walls,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 Findinq/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) an ature(s) of Inspector(s) ) Agency/Office/Phone and Fax Numbers Date
,,,,
Dale Lopez FRO WQ//910-433-3300 Ext.712/ &j y
/0? - ie
- -- ,\:.)
Signature of Managemen Q A Reviewer Agency/Office/Phone and Fax Numbers Date
. <-44241407D siivq/c, 9f
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

3
NPDES
NC0028916
I11 121
yr/mo/day
09/07/08
17
Inspection Type
18ICI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please notice that in the Audit SUMMARY AND COMMENTS section of the report there is a
recommendation and three requirements with due dates. The report indicates that Troy WWTP continues
to meet the pretreatment requirements as outlined in 15A NCAC 2H .0904 (b) for Modified Pretreatment
Programs. Please consider changing the SIU sample location. During the inspection, it appeared that the
24-hour composite sample location would more accurately monitor the SIU wastewater process wastewater
if the 24-hour composite sampler were located at the first manhole instead of at the second manhole, as it is
presently. The reason is that the second manhole may include both the process wastewater and the
domestic wastewater, and the first manhole may not; please first investigate the facility's piping and flow
schematic.Requirements: 1. The STMP is due by October 1, 2009. 2 The IWS is due by December 31,
2009. 3 Please send a copy of the adopted SUO to PERCS Unit. You are commended for your
continued success in maintaining your program. If you have any questions, please contact me at (910)
433-3312. .
Page # 2

NCDENR
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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): Linda Walls
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 315 North Main Street
City Troy, NC Zip Code 27371-3661
Phone Number (910 572-3661 Fax Number [phone] E-Mail Iim9750(uiyahoo.com
5. Audit Date 07/08/2009
6. Last Inspection Date: 07/24/2008 Inspection Type:® PCl ❑ 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.
9. 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
LU INICIO I0I2I8I9I1 I6I I07I08I09I IGI IS I I
(DTIA) (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users (SIUS)? 1
11. Current Number of Categorical Industrial Users (CIUS)? N/A
12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0
14. Enter Higher Number of 12 or 13 0
15. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 0
Semi -Annual Periods (Total Number of SIUs in SNC)
SIUS
CIUS
NOIN
PSNC
16. Number of SIUs with No IUP, or with an Expired IUP
17. Number of SIUs 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
0
0
0
0
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
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21. PRETREATMENT PROGRAM ELEM ENTS REVIEW- Review POTW files, verify POTW has copy of each Program
Element in their File, with all supporting documents and PERCS App oval 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)
11 Yes ❑ No
02/18/2009
/i1 Yes ❑ No
01/31/2014
Industrial Waste Survey (IWS)
(11/25/2005
❑ Yes 4 No
02/02/2005
❑ Yes ❑ No
1
12/31/2009
Sewer Use Ordinance (SUO)
08/07/2008
i4 Yes ❑ No
10/20/2008
►4 Yes ❑ No
Enforcement Response Plan (ERP)
09/04/1992
❑ Yes ►1 No
11/24/1992
/5 Yes ❑ No
Long Term Monitoring Plan '
(LTMP/STMP)
❑ Yes ❑ No
02/18/2009
i1 Yes ❑ No
10/01/2009
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.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? E 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 11/03/08
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.
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
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
'1 S ❑M ❑U
Access to Operable Sampling
Equipment
IS,❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
►Z/S ❑M ❑U
Reference Materials
ZS❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
►Z1S ❑M ❑U
Computer. Equipment (Hardware and
Software)
1S ❑M ❑U
North Carolina Pretreatment Audit Form
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31. Does the POTW have an adequate data management system to run the pretreatment program? Yes ❑ No
Explain Yes or No.
Computer spread sheets
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.
34. Has any one from the public ever requested to review pretreatment program files'? ❑ Yes ® No
if yes. Explain procedure. If no, 1-low 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
PermittinglIndustrial Waste Survey-IWS)
39a...I-low does the POTVII. become aware anew or changed Users?
N/A
Customer Base Changes
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?)
IWS If it seems likely
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
One
Uwharie Env. (permitted, but not as an SIU)
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
Pump & Haul
designated point
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:
, samples drawn,
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.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? /Z1 Yes ❑ No
If yes, what percentage of each parameter
50%
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)
Pollutants specified or that will affect the plant adversely.
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
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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.
Monthly Surcharges
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
Um), 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?
Capel does not need a Slug Control Plan because there is nothing to spill at the SIU
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. 1-las 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 S:IU: ❑ 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? (markall that apply) ❑Increased average flow
❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation 05 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
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
North Carolina Pretreatment Audit Form
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INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU
INSPECTION)
67. IUP Number
0002
68. Does File Contain Current Permit?
►Z/ Yes ❑ No
effective 03/18/09
69. Permit Expiration Date January 1, 2014
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?
►i4 Yes ❑ No
01/02/2009
72. Does File Contain Inspection Completed Within Last Calendar Year?
/ZI Yes ❑ No
12/10/2008
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ■Yes ►@No
b. •Yes _@No
❑Yes❑No®N/A
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. _Yes ■No
b.®Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
i4 Yes ❑ No
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
79. During Most Recent Semi -Annual Period, Did S1U submit all reports on
time?
ElYcs❑No❑N/A
80a. For categorical lUs with Combined Wastestream Formula (CWF), does file
include process/dilution flows as Required by IUP?
❑Yes❑NOON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEIN/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All Limits
15 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 S1U Sampling?
E4 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❑No❑N/A
b.®Yes❑No❑N/A
c.®Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /i4 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 No
North Carolina Pretreatment Audit Form
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FILE REVIEW COMMENTS:
1. The PT Coordinator. said that Capel does not need a Slug Control Plan because there is nothing to spill at the SIU.
The following are industries that have local permits:
• North Carolina Southern Correctional
• . North Carolina Correctional
• Montgomery School
• Uwharrie Landfill
• International Automotive Components (IAC), formerly Collins and Aikman
North Carolina Pretreatment Audit Form
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INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
LNti INIC10 10 1218 19 I1 16 I 1071081091 Il; I IS I I2 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: Dyehouse 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 /ZI Yes ❑ No
D. Sampling Review ® Yes ❑ No
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
Please consider changing the SIU sample location; but, please first investigate the facility's piping schematic. During the
inspection, it appeared that the 24-hour composite sample location would be more accurate in having only the process
wastewater and not include the domestic wastewater if it were located at the first manhole instead of at the second manhole,
presently the sample point.
North Carolina Pretreatment Audit Form
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FILE REVIEW COMMENTS:
Audit SUMMARY AND COMMENTS:
Audit Comments: The files appear to be in good order.
Recommendation:
1. Please consider changing the SIU sample location. During the inspection, it appeared that the 24-hour
composite sample location would more accurately monitor the SIU wastewater process wastewater if the
24-hour composite sampler were located at the first manhole instead of at the second manhole, as it is
presently. The reason is that the second manhole may include both the process wastewater and the
domestic wastewater, and the first manhole may not; please first investigate the facility's piping and flow
schematic.
Requirements:
1. The STMP is due by October 1, 2009.
2 The IWS is due by December 31, 2009
3 Please send a copy of the adopted SUO to PERCS Unit.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Audit COMPLETED BY: Dale Lopez (
Marginal ❑ Unsatisfactory ❑
ti Hassan (PERCS Unit) DATE: 07/24/2009
North Carolina Pretreatment Audit Form
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