NC0028916_Pretreatment Inspection_20040617

NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 17, 2004
Roy Maness, Mayor
Town of Troy
444 North Main Street
Troy, North Carolina
SUBJECT: Pretreatment Compliance Inspection
Town of Troy WWTP
NPDES Permit No. NC0028916
Montgomery County
Dear Mayor Maness:
Enclosed you will find a copy of the. Pretreatment Compliance Inspection Report' for the
inspection conducted on June 8, 2004. Present at the inspection wereGray Walls (Public Works
Director), Linda Walls (Pretreatment Coordinator), Deborah Gore. (DWQ-Pretreatment Unit),
and Dale Lopez (DWQ-FRO). 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.
The report is self-explanatory and contains observations, requirements and recommendations. If
you or your staff have any questions or require clarification, please do not hesitate to contact me
at [phone] or Deborah Gore at [phone], extension 593.
Sincerely,
Dale Lopez
Environmental Specialist
DG/DL: DL/dl
Enclosures: Pretreatment Compliance Inspection Report
cc: Gray Walls, P.E., Town of Troy, Public Works Director
Deborah Gore, DWQ Pretreatment Unit
225 Green Street - Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] \ FAX: [phone] Internet: www.enr.state.nc.us/ENR/
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
One.
NorthCarolina
Vaturallj

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
FAYETTEVILLE REGIONAL OFFICE:
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: Town of Troy
2. Control Authority Representative: Gray Walls, P.E./Linda Walls
3. Title(s): Public Works Director/Pretreatment Coordinator
4. Last Inspection Date: May 23, 2003 •Inspection Type (Circle One): PCI
es
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? / No
6. Is POTW under an Order That Includes Pretreatment Conditions? Yes / No
Order Type And Number: Are Milestone Dates Being Met?Yes / No / IN/Al
PCS CODING
Trans.Code
!Audi
Program NPDES Number • MM/DD/YY Inspec.Type
J NI CIO 10 12 18 19 [1 16 1 06'/08 /04 f P1
(D11A) : (TYPI)
7. .Current Number of Significant Industrial Users (Sills)?
Inspector
(INSP)
Fac.Type
(FACC)
SIUS
8. Current Number of Categorical Industrial Users (CIUs)?
CIUS
9. . Number of SIUs Not Inspected by POTW in the Last Calendar Year?
10. Number of SIUs Not Sampled by POTW in the Last Calendar Year?
11. Enter the Higher Number of 9 or 10.
NOIN
12. Number of SIUs With No IUP or With an Expired IUP?
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?
16. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods?
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
`failure in July 20031If Yes, What are the parameters and how are these problems being
addressed? Candor Hosiery was using ammonium sulfate in its process, this caused the pH WI
be too low. It affected the POTW's treatment by stripping thealkalinity, it caused an
increase of the ammonia at the POTW's influent to be greater than 100 mg/L. Candor
Hosiery then switched from ammonium sulfate to acetic acid, which remedied the low pI�
and nitrification problems and it didn't require alkalinity uptake.!
Since the Last PCI, has the POTW had any Problems Related to an Industrial Discharge
(Interference, Pass -Through, Blockage, Citizens' Complaints, Increased Sludge Production,
18. Etc.)?
If Yes, How Are These Problems Being Addressed?
0 SNPS
!Aquatic Toxicity!
!YES!
YES
NO
oi

19. Which Industries have been in SNC during either of the Last 2 Semi -
Annual Periods? Have any Industries in SNC (During Either of the Last
2 Semi -Annual Periods) not been Published for Public Notice?
(14ay refer to PAR if Excessive SIUs in SNC)
SNC for Limits: 0
SNC for Reporting: 0
Not Published:
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?
0
None
YES
PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headwork Analysis (HWA)
06/04/04
01/2009
Industrial Waste. Survey (IWS).
10/29/98
09/30/04
Sewer Use Ordinance (SUO)
06/04/97
1/31/2005
Enforcement Response Plan
(ERP)
11/24/92
Long Term Monitoring Plan
(LTMP
06/04/04
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies?
Will change to a STMP
23. Should any Pollutants of Concern be Eliminated From or Added to the LTMP?
If Yes, which ones? Eliminated: Added:
24. Are Correct Detection Levels being used for all LTMP Monitoring?
(Yesi
/ No
Yes /
tNc
/ No
25. Is the LTMP Data Maintained in a Table or Equivalent? / No Is the Table Adequate? f Yes / No
'Yes

INDUS IIUAL UJL.ic rL'
26. User Name
iclril1 tux-, r1L.r. AVER V .a..,.
1. Candor Hosiery
2. Capel
3 • -
27. IUP Number
0007 I
0002 -
28. Does File Contain Current Permit? -
a. Isles! / No
(Yesj(No
29.
Permit Expiration Date?
01/O1/09
O1/Ol/09
30.:.
Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
N/A
..
N/A
31. Does the File Contain Permit Application Completed Within One Year
IYes1/ No
E2o
Prior to Pemut Issue Date?
108/18/03I
109/03/031
32. • . • Does the File Contain an Inspection Completed Within. Last Calendar '
1Yes
/ No.
E , o
Year?
P5/27/03
105/20/03
33. • a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW) `
a. Yes / W
b. Yes /
a Yesg
b. Yes/®- .
And 433 TTO Certifiers, Does The File Contain A
Yes / No
Yes/No N/A1
as
34. For 40 CFR 413
Toxic Organic Management Plan (TOMP)?
35. a. Does the File Contain Original Pennit Review Letter from the
a.YYes f / No
RMo
Division?
b. All Issues Resolved?
b.1Yes1/ No N/A
b. 'Yes
36. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP?
tYesl / No
E. o
37. Does File Contain POTW Sampling Chain -Of -Custody's?
'Yes
/ No
R22o
Located at the POT*
38. During the Most Recent Semi -Annual Period, -Did the SIU Complete
lYYes1 / No N/A
o N/A
its Sampling as Required By IUP?
POTW does all of the sampling
39. Does Sampling Indicate Flow or Production?' Located at the POTW
'Yes' / No N/A
1Yes/No
• 40 . During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
'Yes
/ No .
o
4o limits violations'
POTW Notified by SIU (Within 24 Hours) of All Self-
a.Yes / No/ IN/AI
a.Yesa./ No/
41. a. Was the
. -
• Monitoring Violations •
Industry Resample Within 30 Days?
b.Yes / No/ .1N/A1
Yes / No/
b. Did
b
No Violations'
tNoViolations'
Violations (Per ERP)?
Yes / No tN/A1
Yes/No tN/A)
- 42. Was the SIU Promptly Notified of any

43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
Yes /
No
Yes
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
Yes /No/
N/A
Yes/No IN/Al
45. Does the File Contain Penalty Assessment Notices?
Yes / No IN/Al
Yes/No
N/A1
46. Does the File Contain Proof of Penalty Collection?
Yes / No
N/AI
Yes/No 1NUA4
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
a.Yes / No
N/A
Yes/No 4/A1
b.Yes / No
N/A
48. Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You? •
Yes /
No
Yes/i
FILE REVIEW COMMENTS
PCI Comments:
Conscientiously run program.
It is expected that Handi-Sanitary District will be discharging to Troy in the future.
Requirements:
SUO --- Due to regulatory changes, the maximum fine in the SUO is now $25,000. Guidance for making this change will be available
on the Pretreatment web site within the next 4 weeks. Do not make this change without consulting the guidance. If you do not have
internet access, call the Pretreatment Unit for hard copy. Submit the updated SUO to the Pretreatment Unit by January 31, 2005.
The Town of Troy is a Modified Program and as such is only required to conduct a Short Term Monitoring Plan (STMP) for
development of the site specific HWA. Troy has voluntarily been conducting Long Tenn Monitoring. As discussed at the inspection,
Troy wishes to reduce the monitoring frequency to 1/ qtr for 4 consecutive quarters the year prior to the HWA. A review of the Plan
submitted in January will be sent under separate cover to address this change. Please note that EPA Method 1631 for mercury must be
used for effluent mercury sample analysis.
Note the due date for the Industrial Waste Survey — 9/30/2004.
Recommendations:
Pretreatment records starting before 1999 may be discarded at your discretion.
NOD: YES
NOV: YES,
QNCR: YES
POTW Rating: S .factory ✓ Marginal Unsatisfactory
PCI COMPLETED BY: Dale
N d Si tore of Reviewer
..........zlf
Paul ts
ialist / DeborahGore. Environmental. Engineer Date:06/17/04
Agency/Office/Telephone
Date
6// 7» S

INDUSTRY INSPECTION CODING:
INo Industrial Inspection was conducted during the PCI Inspection
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
Nj 1111111.111
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4. Industry Contact:
Phone:
Fax:
/ / L11
(DTIA) (TYPI) (INSP) (FACC)
LS 1 L� 1
5.Does the POTW use The Division Model Inspection Form or Equivalent?
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
B Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments: