NC0028916_Pretreatment Audit_20030529

•
A7A
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
May 29, 2003
Roy Maness, Mayor
Town of Troy
444 North Main. Street
Troy, North Carolina
SUBJECT: Pretreatment Audit Inspection
Town of Troy WWTP
NPDES Permit No. NC0028916
Montgomery County
Dear Mr. Maness:
William G. Ross, Jr., Secretary
Alan Klimek, Director
Division of Water Quality
Enclosed you will find a copy of the Pretreatment Audit Inspection Report for the
inspection conducted on May 22, 2003 at the office of the Public Works Director. Present at the
inspection were Gray Walls (Public Works Director), Linda Walls (Pretreatment Coordinator),
Paul Rawls (DWQ-FRO Water Quality Regional" Supervisor), 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.
As a reminder, every five years the IWS and HWA need to be updated. They are due at
the Pretreatment Unit in Raleigh by the month of October 2003. Enclosed with this report is the
schedule frequency and sampling plan copied from the N.C. Pretreatment Comprehensive Guide
for Modified Pretreatment Programs. The STMP for Modified PT programs was originally
designed with 4 consecutive days of monitoring at the WWTP influent and effluent. However, the
Division is now strongly recommending one influent and effluent sample each quarter for 4
quarters. The Division presents a one -day HWA training session to instruct POTW pretreatment
staff and consultants in developing an HWA. The PT Unit holds them approximately once every
two months, usually alternating between the eastern half and western half of the state. Please
contact the PT Unit if you wish to attend an HWA workshop.
The report is self-explanatory and contains observations and recommendations. If you or
your staff have any questions or require clarification, please do not hesitate to contact me at (910)
486-1541.
ncerely,
atc
Dale Lopez
Environmental Specialist
Enclosures: Pretreatment Audit Inspection Report
LTMP Frequency for STMP for Modified PT Programs
cc: Gray Walls, P.E., Town of Troy, Public Works Director
DWQ Pretreatment Unit
rayetteville Regional Office
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone]/FAX: [phone] Internet: ww-w,v.enr.state.nc.usiENR
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled \ 10% Post Consumer Paper

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Troy Wastewater Treatment Plant
2. Control Authority Representative(s): Gray Walls/ Linda Walls
3. Title(s): Public Works Director/Pretreatment Coordinator
4. Address of POTW:
Mailing 444' North Main Street
City Troy Zip Code 27371
Phone Number [phone]; Mobile [phone] Fax Number
5. Audit Date 05_/ 22 / 03
6. Last Inspection Date: 05 / 02 / 02 Inspection Type (Circle One):
PCI
Audit
7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? Yes / No
If No, Explain.
Will start the HWA soon. Will send out the 1WSs soon. NPDES permit will soon be up for renewal.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? Yes /
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? Yes /
No
No
N/A
Order Type and Number: Are Milestone Dates Being Met? Yes / No
Parameters Covered Under Order
N/A
PCS (WENDB)Coding
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac,.Type
I N I I N_I C_I_0 I_0_I 2 18_I_9_1_1 _1_6_I 05/_22_/_03_ I G I IS
(DTIA) (TYPI) (INSP)
10. Current Number of Significant Industrial Users (SIUS)?
11. Current Number of Categorical Industrial Users (CIUS)?
12. Number of SIUS Not Inspected by POTW in the Last Calendar Year?
13. Number of SIUS Not Sampled by POTW in the Last Calendar Year?
14. Enter the Higher Number of 12 or 13
15. 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)
16. Number of SIUS with No IUP, or with an Expired IUP
I 1 1
(FACC)
0
0
0
0
0
0
SIUS
CIUS
NOIN
PSNC
17. Number of SIUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods
0
MSN
C
18. Number of SIUs in SNC for Limits Violations During Either of the Last 2 Semi -Annual Periods
19. Number of SIUS in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods
0
0
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
0
SNIN

PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files and complete the following:
Program Element
, Date of Last Approval
Date Next Due, If Applicable
Headworks Analysis (HWA)
10/20/98
Industrial Waste Survey (IWS)
10/29/98
Sewer Use Ordinance (SUO)
06/04/97
Enforcement Response Plan (ERP)
11/24/92
Long Term Monitoring Plan (LTMP)
10/20/98
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? Yes /
If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Yes / No
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? Yes / No
If yes, Explain.
24. Date of Last SUO Adoption by Local Council IQ / 17 / 97
25. Have you had any problems interpreting or enforcing any part of the SUO? Yes /
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? Yes /
If no, POTW must send copy within 30 days.
Nol
No
N/AI
\T/A
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudications, improper enforcement, etc.)?
Yes / No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A

Resources
29. Please Rate the Following:
S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
_ .
S M U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
QS M U
Access to Operable Sampling
Equipment
_
S M U•
Availabity of Funds if Needed for
Additional Sampling and/or Analysis
1Jl M U
Reference Materials
_
S M U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
_
S M U
Time constraints
Computer Equipment (Hardware and
Software)
S M U
30. Does the POTW have an adequate data management system to run the pretreatment program?
/ No Explain Yes or No.
Yes
All records are put into computer EXCEL spreadsheets on a monthly basis
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
POTW charges the S1Us for Laboratory testing costs and surcharges
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
Yes / No If yes, Explain.
33. Has any one from the .public ever requested to review pretreatment program files? Yes /
If yes, Explain procedure. If no, How would the request be addressed?
No
34. Does the POTW have a procedure in place that addresses requests by an industry for certain information to remain confidential?
Yes / No If yes, Explain. Has never been requested by the SIUsj
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes / No
36. Is the public notified about changes in the SUO or Local Limits? Yes /
37. Were all industries in SNC published in the last notice? Yes / No
No SIUs were in SNC
No --- Haven't been changes
N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and
therefore require a permit? (Who is an SIU?)
By testing the SIU effluent water and by SIU flow measurements and usage

39. Does the POTW receive waste from any groundwater remediations (petroleum, CERCLA) or landfill leachate? Yes /
If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
INol
40. Does the POTW accept waste by (circle if applicable) f TruclJ Dedicated Pipe
Septic tank waste only
41. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required)
Discharge at Designated point only, and manifests are required
42. How does the POTW allocate its loadings to industries? Circle One
1.) Uniform Limits 2.) Historical Industry Need 3.) By Surcharge 4.) Categorical Limits 5.) Other
Explain Other:
Based on the industrial needs
43. Review copies of current allocation tables for each WWTP. Are there any over allocations? Yes /
If yes, What parameters are over allocated?
No
44. If yes to ##43, What is being done to address the over allocations? (short term IUPs, HWA to be revised, pollutant study, etc.)
45. Does the POTW keep pollutant loading in reserve for future growth / safety?
If yes, what percentage of each parameter 10 %
Yes
/ No
The POTW is underloaded
46. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes /
If yes, Explain.
No
47. 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)
48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
Once per month for all SIUs, also depends on flows
Permit Compliance
49. Does the POTW currently have or during the past year had any permits under adjudication? Yes /
If yes, Which Industries, and what was (will be) the outcome of the adjudication?
N o]
50. 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.
The computer flags the violations
51. Does the POTW use the Division's model inspection form or equivalent? f Yes / No
If no, Does the POTW form include all DWQ data? Yes / No
52. Were all SIUs evaluated for the need of a slug and spill control plan during their most recent inspections'? Yes /
If no, Explain.
All SIUs have plan already
53. What criteria are used to determine if a slug control plan is needed?
Potential for a large spill, or degree of toxicity the waste stream would be
54. What criteria does the POTW use to review a submitted slug control plan?
Determining if the slug/spill can be stopped before reaching the POTW
No

Sampling convenience and a location where only the SIU wastewater is present
56. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: swirling the sample bucket uniformly) Yes / No
If yes, Explain.
The POTW does all of the sampling (by Grey Walls)
57. Who performs sample analysis for the POTW for
Metals Meritech
Conventional Parameters Meritech
Organics Meritech
Splits Carolina Environmental Laboratories (in Sanford)
58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Only commercial Chain -of -Custody sheets used
Long Term Monitoring Plan (LTMP) and Headworks Analysis (HWA)
59. Is LTMP maintained ina table? Yes / No
Review Data and Explain.
60. Do you complete your own headworks analysis (HWA)
Yes
/ No
If no, Who completes your HWA? Phone ( )
61. Do you have plans to revise your headworks in the near future? Yes / No
If yes, What is the reason for the revision? (circle one) -
1.) Increased average flow
4.) More LTMP data available
Explain.
2.) NPDES limits change
5.) Resolve over allocation
62. In general, what is the most limiting criteria of your HWA?
2.) Pass Through 3.) Sludge Quality
1.) Inhibition
3.) Other
6.) 5 year expiration
63. Do you see any way to increase your loadings in the future (Example: obtaining more land for sludge disposal)? Yes /
Explain.
Summary
No
64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
V (3 IUP FILE REVIEWS
v 65. User Name
1. Candor Hosiery
2. Capel
3.
66. IUP Number
0007
0002
67. Does File Contain Current Permit?
Yes
/ No
Yes / No
Yes / No
68. Permit Expiration Date
01/01/04
01/01/04
/
69. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
70. Does File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
Yes
/ No
Yes / No
Yes / No
71. Does File Contain an Inspection Completed Within Last Calendar
Vear?
_
Yes
/ No
Yes / No
Yes / No

72. a. Does the File Contain a Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes / SV
b. Yes&
a. Yes /(ilo
b. Yes o
a. Yes / No
b.-Yes /No
73. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
Organic Management Plan (TOMP)?
Yes / No 7 /A
_
Yes /No / /
Yes / No /
N/A
74. a. Does File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
a. e / No
b. • s / No / /A
// G 4� Ct'g
a. t / No
b. Yesj/ No /
phi/N/A
a. Yes / No
b. Yes / No /
75. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP'?
es / No
es' No
Yes / No
76. Does File Contain POTW Sampling Chain -Of -Custodies?
Yes / Noes
No
Yes / No
77. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required by IUP?
es No / N/A
es No / N/A
Yes / No /
N/A
78. Does Sampling Indicate Flow or Production?
6,..F;)/ No / N/A
Yes No / N/A
Yes / No /
N/A
79. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Yes /No
`.---
Yes) No
Yes / No
80. a. Was the POTW Notified by IU (Within 24 ours) of All Self-
Monitoring Violations? 1'7 ?.) 0-LyN,� 27/,( ,
b. Did Industry Resample Within 30 Da s?-3�/`),0y 2-G';t4
a. Yes / No / /Ai
b Ye)No
a. Yes / No / /A�
b. ey/ No
a. Yes No'
N/A
b.Yes / No
81. Was the SIU Promptly Notified of Any Violations (Per ERP ?s
/ o / N/A
(7....e.A / No / N/A
Yes / No /
N/A
82. During the Most, Recent Semi -Annual Period, Was the SIU in SNC?
Yes / ,I
No)
Yes / No
83. During the Most Recent Semi -Annual Period, Was Enforcement
Taken as Specified in the POTWs ERP?
Yes1/ No / N/A
�,' _
,_____Yes
( Yes N� N/A
--
Yes / No /
N/A
84. Does the File Contain Penalty Assessment Notices?
Yes / No N/A'
Yes / N / N/A
Yes / No /
N/A
85. Does The File Contain Proof Of Penalty Collection?
.
Yes / No ' i /A)
Yes / N / N/�J
Yes No i
NIA
86. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a. Yes / No i _ )
b. Yes / No NLA
a. Yes / No ' .
b. Yes / No N/
a. Yes / No /
N/A b. Yes /
No/N/A
87. Did the POTW Representative Have Difficulty in Obtaining Any of
This Requested Information Foi You?
Yes (No)
`--
Yes No
Yes / No
FILE REVIEW COMMENTS:
1. The Prison & Troy Lumber, and the other old SIUs still are required to do sampling, just as a regular SIU.
2. Concerning the SUO, the POTW might need to review the grease issue.
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements: IWS & HWA are due this year (please see the cover letter of this report).
Recommendations: Suggest that the word "Notice " be added to the form letters that the POTW sends to the SIUs for limits
violations.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory VVIarginal
�I3nSat' fc tory
Audit COMPLETED BY: Dale Lopez �.�C 4`�� I DATE: 05/29/03

Reviewer
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
N I j N ICI 0 1 0 1 2 18 1 9 I l 1 6 1 1 05 1 22 103 ( j I 1 I. S ( 1 2 1
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Candor Hosiery
2. Industry Address: 105 Poole Road. Troy, NC 27371
3. Type of Industry/Product: Textile
4. Industry Contact: Wayne Gardner. Title: Maintenance Manager
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
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments:
Ladies socks are manufactured. Only direct dyes are used. The salt used is the type containing YPS. No WSO or other wetting agents
are used. The SIU's domestic sewage goes directly to the POTW collection system. In the future, all white socks will be processed in
the Town of Robbins. The products needing the chlorine process will remain in Troy's SIU site. The production consists of 70% white
products and 30% dye (as dark colors). Production at this plant is at a rate of 116,000 dozen socks in a 48 hour period per week.

MODIFIED PROGRAMS Application
Activated Sludge/Aerobia Digester with Land �
STMP Model (continued)
F. : Sampling' Frea n v
Sampling Point
1- Influent
2 - Effluent
3 - Activated
Sludge Basin
4 - Sludge to
Disposal
5, 6 & 7 - SIU's
G. Sampling Plan
P.O.C.
As.
Cd
Cr
Cu.
Pb
Hg
Mb
Ni
Se
Flow
%solids
BCD
TSS
WithinlYear Before HWA
4 consecutive.. workdays
(Monday -Thursday)
4 consecutive workdays
(Monday - Thursdal)
Once
Per Sludge Permit and . 503
regulations
Per SIU Permit
(Recommended for all POC's once)
Pt. 1
x.
x
x.
x
x
x
x
x
x
x
x
x
Pt. 2 Pt.. 3
x
x
x
x
x
x
x
x' x
x x
x
x
x
Pt. 4
x
x
x
x
x
x
x
All POC's should be indicated on the sampling plan."
Chapter: LTMP Guidance
Filename: STMP model 940607
Revision Date: August 1, 1994
Chapter 4
Appendix C
Page .2