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NC0037508_Pretreatment Inspection_20120430
Av7A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman Governor Director Secretary April 30, 2012 Janna Scherer Pretreatment Coordinator/Lab Supervisor 1094 Addor Road Aberdeen, NC 28315 SUBJECT: Pretreatment Compliance Inspection (PCI) . Moore County Water Pollution Control Plant NPDES Permit No. NC0037508 Moore County Dear Ms. Scherer: Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the April 27,. 2012 inspection of the pretreatment records and files. The report indicates that Moore County Water Pollution Control Plant meets the pretreatment requirements as outlined in 15A NCAC 2H .0900. We appreciate your co-operation and your continued efforts with the pretreatment program. Your excellent record keeping and your organization of the Pretreatment files were outstanding. Please keep up the good work with your pretreatment program. If you have any questions concerning this report, please do not hesitate to -contact me at (910) 433-3312. Dale Lopez Environmental Specialist Enclosures: Pretreatment Compliance Inspection Report EPA Water --Compliance Inspection Report Moore POTW NOV for pH sent to Pinnacle Furnishings (03/02/2011) Moore POTW NOV for Zinc sent to Thermal Metal (04/13/2011) Themal Metal response letter (05/03/2011) for Zinc NOV Moore POTW NOV for Nickel sent to Theuuial Metal (09/09/2011) cc: PERCS - Pretreatment Unit (Monti Hassan) 03(0D.a`�1.- opez)), J N110 225 Green Street -Suite 714 —Fayetteville, North Carolina 28301-5043 Phone: 910-433-33001 FAX: 910-486-0707 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.orq An Equal Opportunity 1 Aff rmative Action Employer One NorthCarolina Naturally United States Environmental Protection Agency EPA Washington, D.C. 20460 Water Compliance Inspection Repnrt 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 15 I 31 NC0037508 i 11 121 12/04/27 117 Type Inspector Fac Type 18I p I 19I S I 20I II 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 166 Remarks 211I1_I 1 1 1 1 III1II11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 671 2.0 169 70 14 I 711 I 72 I N I 731 1 174 751 I I I I I 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) Moore County WPCF 1094 Addor Rd Aberdeen NC 28315 Entry Time/Date 10:00 AM 12/04/27 Permit Effective Date 10/12/01 Exit Time/Date 01:30 PM 12/04/27 Permit Expiration Date 14/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Rex A Downs/ORC/910-436-2836/ Other Facility Data - Name, Address of Responsible Official/Title/Phone and Fax Number Contacted George Yankay,1094 Adder Rd Aberdeen NC 28315//910-281-3146/ 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) a nature(s) of Inspector( ) Agency/Office/Phone and Fax Numbers Date Dale Lopez FRO WQ//910-433-3300 Ext.712/ a%,0t CieZ Signature of Managgem��entQ A Reviewer Agency/Office/Phone and Fax Numbers Date G/R1C.Gf ,,L i gC � `,l ii EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES ' yr/mo/day Inspection Type 31 NC0037508 111 121 12/04/27 117 18IPI (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 April 27, 2012 inspection of the pretreatment records and files. The report indicates that Moore County Water Pollution Control Plant meets the pretreatment requirements as outlined in 15A NCAC 2H .0900. We appreciate your co-operation and your continued efforts with the pretreatment program. Your excellent record keeping and your organization of the Pretreatment files were outstanding. Please keep up the good work with your pretreatment program. If you have any questions concerning this report, please do not hesitate to contact me at (910) 433-3312. 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: Moore County WPCP 2. Control Authority Representative(s): Janna Scherer 3. Title(s): Chemist/PT Coordinator/FOG Coordinator 4. Last Inspection Date: 07/21/2011 Inspection Type (Check One): El 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? El ES ® NO Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO PCS CODING Trans.Code Main Program Permit Number I NIC 101013171510181 MM/DD/YY J 04127 1 12.1 (DTIA) Inspec.Type I P I (TYPI) Inspector 1 S 1 (INSP) Fac. Type l I (FACC) 7. Current Number Of Significant Industrial Users (SIUs)? 3 SIUS 8. Current Number Of Categorical Industrial Users (CIUs)? 3 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 reNO ❑YES aNO Limits: Reporting: lished: 0 0 0 0 LIYESNO LTMP/STMP FILE REVIEW: 22. Is LTMPiSTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO 24. See Comment #1 Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? 25. All LTMP/STNIP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO DWQ Inspector. please verify yourself! 26. if NO to 23 - 26, list violations ❑ YES ❑ NO 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES © NO NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW tiles, verify POTW has copy Ot Program Element in their files. complete with supporting documents and copy of PERCS Approval Leiter. and dales consistent with Pro,ram Info: Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/08/10 0 Yes ❑ No 02/22/11 ►Z1 Yes ❑ No 11/01/2015 Industrial Waste Survey (IWS) 08/26/08 0 Yes ❑ No 11/05/08 ►II Yes ❑ No 09/01/2013 Sewer Use Ordinance (SUO) 05/31 /0 7 E Yes ❑ No 10/16/07 ►1 Yes ❑ No 12/31/2012 Enforcement Response Plan (ERP) 10/30/08 el Yes ❑ No 11/19/08 Yes ❑ No Long Term Monitoring Plan (LTMP) 06/28/04 a Yes ❑ No 07/13/04 ►XI Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION 29. User Name 1. Erico 2. Pinnacle 3. Thermal Metals 30. IUP Number A005 A007 A008 31. Does File Contain Current Permit? Yes, eff. 07/01/08 ►ZI Yes eff. 07/01/10 I1 Yes eff. .07/01/10 32. Permit Expiration Date 06/30/13 06/30/15 06/30/15 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 433 433 34. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? /I1 Yes ❑ No 12/20/07 /1 Yes ❑ No 12/15/09 X1 Yes ❑ No 12/24/09 35. Does File Contain an Inspection Completed Within Last Calendar Year? /i1 Yes09/27/11 I1 Yes 9/16/11 /I1 Yes09/30/11 36. a. Does the File Contain a Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) a. ►EYes ■No 10/19/10 a. ►. Yes ■No 12/18/09 a. @Yes ■No 01/15/09 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. 0Yes ■No b.❑Yes❑No❑N/A a. EYes No b.❑Yes❑No❑N/A a. _EYes ■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? ►ZI Yes ❑ No ►Z1 Yes ❑ No iI Yes ❑ No 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ►ZI 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? EYes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A 11 b. During the Most Recent Semi -Annual Period, Did SIU submit all reports on time? EYes❑No❑N/A EYes❑No❑N/A EYes❑No❑N;A 42a. For categorical Ills with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 42b. For categorical lUs with Production based limits, cloes file include production rates and/or flows as Required by IUP? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? ►Z1 Yes ❑ No /i1 Yes ❑ No I Yes ❑ No No violations pH 02/14/12 Zn in Mar 2011 Ni in Aug 2011 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑Yes❑NoEN/A ❑Yes❑No®N!A ❑Yes❑NoEN'.;A 44. a. Was the 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 within 30 days of becoming aware of SIU limit violations in the POTW's sampling of the SIU? a.❑Yes❑NogN/A b.❑Yes❑NogN/A c.❑Yes❑NogN/A a.®Yes❑No❑N/A b.gYesDNo❑N/A c.❑Yes❑NogN/A a.gYes❑No❑N/A b.gYes❑No❑N/A c.❑Yes❑NogN/A 46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ►i4 No ❑ Yes No ❑ Yes iI No 47. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties; timing, etc.)? ❑Yes❑NoEN/A EYes❑No❑N/A EYes❑No❑N/A 48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 50. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? a.❑Yes❑NogN/A b.❑Yes❑NogN/A a.❑Yes❑NogN/A b.❑Yes❑NogN/A a.❑Yes❑NogN/A b.❑Yes❑NogN/A 51. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ❑ Yes No ❑ Yes 0 No ❑ Yes I No NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2 FILE REVIEW COMMENTS: 1. (See question #23) Chromium (<0.005 mg/L) Arsenic (<0.010 mg/L) Cadmium (<0.002 mg/L) Lead (<0.005 mg/L) Molybdenum (<0.005 mg/L) Nickel (<0.010 mg/L) Selenium (<0.010 mg/L) Silver (<0.005 mg/L) Cyanide (<0.005 mg/L) NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3 NO INDUSTRY INSPECTION PERFORMED DURING THIS PRETREATMENT COMPLIANCE INSPECTION INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number 1 N_1 1 1 1 1 1 11 1. Industry Inspected: 2. Industry Address: MM/DD/YY Inspec.Type Inspector Fac. Type ► [ 1 I 1 1 1 I l J S l 1 21 (DTIA) (TYPI) (INSP) (FACC) 3. Type of Industry/Product: 4. Industry Contact: Phone: Title: Fax: 5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ 'VES ❑ 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 E NO . D. Sampling Review ❑ YES ❑ NO E. Exit Interview ❑ YES ❑ N(� Industrial Inspection Comments: OVERALL SUMMARY AND COMMENTS: Comments: We appreciate your co-operation and your continued efforts with the pretreatment program. Your excellent record keeping and your organization of the Pretreatment files were outstanding. Please keep up the good work with your pretreatment program. Requirements: None Recommendations: Please keep up the good work. NOD: ❑ \' ES ® NO NOV: ❑ YES ENO QNCR: EYES ® NO POTW Rating: Satisfactory ✓ Mar Un tisfactory PCI COMPLETED BY: Dale Lopez DATE:. April 30, 2012 REVIEWED BY: Belinda Henson DATE: NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4 j' -iliac 'Works 1• a terToClitt.ion Control -Plant 1 )4 �a.ddor'Roacl- -erdeen, -NC 28315 y County of .?Moore April 13, 2011 Jerry Ritter Thermal Metal Treating, Inc 9546 Hwy 211 E PO Box 367 Aberdeen, NC 28315 Subject: NOTICE OF VIOLATION Permit No. A008 Dear Mr. Ritter: (97o) 281-3746- Tone �/ 6-)10) 281-2047- Fax A review of Theinial Metal's monitoring data for March 2011 showed the following violation(s): Parameter Date Limit Value Reported Value From Industry Reported Value From PO,T.W,. Limit Type Zinc 3/10/11 2.61 mg/1 21.7 ni Daily Maximum Exceeded Zinc 3/10/11 1.48 Trig/1 21.7 mg/1 Monthly Average Exceeded • Remedial actions must be taken to correct the problem. The Moore County Water Pollution Control Plant may pursue enforcement action for this and any additional violations in accordance with the Enforcement Response Plan. Per Section 8.1 of the Moore County Sewer Use Ordinance, Thermal Metal Treating shall respond in writing within thirty (30) days as to the cause of these violations and what corrective_ actionswill be taken to prevent future violations. If you have any questions, please contact me at 910-281-3146. Sincerely, anna Scherer, County of Moore, Pretreatment Coordinator Cc: Mr. George Yankay, County of Moore, Superintendent Mr. Dennis Brobst, County of Moore, Public Works Director I• J Pit Tic: 1,Vorks -Water Po((ction Control- P[ant fo94 Mcfor Road .berdeen, :NC 28315 County of .Moore March 2, 2012 Jack Berggren Pinnacle Furnishings, Inc. 10570 NC 211 E Aberdeen, NC 28315 Subject: NOTICE OF VIOLATION Permit No. A007 f910) 281-3146- Phan. (910) 281-2047- fax Dear Mr. Berggren: A review of Pinnacle Furnishings monitoring data for February 2012 showed the following violation(s): Parameter Date Limit Value Reported Value From POTW Limit Type pH 2/14/12 6.0-11.5 s.u. 5.55 s.u. . Limit Exceeded Remedial actions should be taken to correct these problems. The Moore County Water Pollution Control Plant may pursue enforcement action for this and any additional violations in accordance with the Enforcement Response Plan. If you have any questions, please contact me at 910-281-3146. Sincerely, Janna Scherer, County of Moore, Lab Supervisor/Pretreatment Coordinator Cc: Mr. George Yankay, County of Moore, Superintendent Mr. Randy Gould, County of Moore, Public Works Director L4A-60-- : U1 ry.um-ploore A c • 1-401 1-'Llk1k1Z.1 VI Li V15 -010 9546 HWY 2:11 EAST - ABERDEEN, NC 28315 THERMAL METAL TREATING, INC. Your gateway to innovative metal proae'sing technology Af?.'W PO BOX 357 - ABERDEEN, NC 25315 P: 919 — 944 -306 F; 910 — 944 -3280 MMtbarfl)N.M0%.31,c0r0 Mgy Janne Scherer County of Moore Prettmeordin@tgr DENR -FAYETTEVILLE REGIONAL OFFICE re.ant .Q. • RFC vFD Dear Janna, AP 3 0 2012 imcaidc-ma-ra gi MAY 1 2011 S_JJ BY: ...... ............. In responee tQ the Notice cf ViqlgtIgn - Permit No, d,VM,, )191,1 sent Thermal Metal Treatica Inc. — TMT. I am sending you this letter of explanation of:the violation and remedial action taken to prevent any further occurrence. April our OaSkie Jaboratary .f.g,r treated waste water quality testing, Merited), Inc, of Reidsville, NC was sent our normal monthly test sample. Their test indicated a zinc reading 21.7 mgll 'which far exceeded the maximum reporting limit and any zinc reading we had „ever crecorded internally. TMT's normal sampling procedure. for all treated waste water is as follows: Using a .calibrated Hach 201.0 .spectrophotometer,lests are made and recorded :for copper, f1.19K0kP flW.t.190.91:9.thw9.§tq.14\903- tr:p.qtr:1,1e91 t9119Y.Vitlg trem.rt9.YPrifY compliance before any discharge to .the municipal system is performed: TMT's internal records indicateho reading have. ever reached the levels reported by Meritech on the .s,,ibject ;batch tot, 1?ethre or aftertre.atment. - See typical TMT recorded readings on the attached internal recOrdS for March 2011., .in feyiev.ying-th.e :steps leading ,:up,to The lre.atme.nt of :the :batch of waste water that the Meritech sample was taken from, not-1'N out of the Qrdinary.was found in the typ.e of product processed during the production'cycle that generated this waste water.' No changes in.the chemicals or methods of treatment were used that may.have led to an Inordinately high 'zinc. levet There is. np. assignable cause that could be established for the extremely high.z.inc madings based o.n the history or treatment of this batch lot. Remedial -action by TMT includes All samples from now on, taken from our treated waste stream, will have a duplicate sample taken in approved containers. One will be submitted to Meritech or another certified laboratory and the other stored in a dedicated refrigerator at TMT, until PNclicla 9.t Q.9111P.1,1,P.P.V is?.Y TM.T, This 09W for an d ton1 test sample to be checked if the .original sample results find any .questionable readings. -Le-. . V,. -14'..LL 1 A9,44:.3 :Your gateway to Innovative metol processing technology • 9546 HWY 211 EAST - ABERDEEN„ NC 2015 THERMAL METAL TREATING, INC. PO BOX 367 - ABERDEEN, NC •28315 P; 910 - 944 -3636 F: 910 - 944 -3280 .i§C) 9102 wpwAgralOrngOlam Although nothing indicated the TMT-spectrophotometer registered a false reading for ubject-Zinc from calibratio.n test to ,a monthly one. • Meritech .Lab. picked up the subjects,ample on March .3, '2011. and we didn't receive the tPaVtt,5. Uhtik AQi 2$, 2011; are. 1:.,cicipppng WOP.9.h 19?.C1.00] IP P. timer mariner to allow for the dupliCate sample to be tested before the calendar month expires. 99.0X.Pr ;Pf9Y9 ? faultt9 Thi 99.C..4.1fr91.1P either internally or with Meritech's results and therefore must leave this with only being able to reinforce our current system with some redundancy and higher level of calibrations to .catch ,a,futu re instance of insufficient flocking or bad test procedures from our testing vendor. Best re.gards, Jerry Ritter President 1 Metallurgist ,77 L.' APR 3 0 20'12 DENR -FAYETTEWLLE REGIONAL OFFICE PutiCic Works Water POCCtttion Control Plant 1094 -addor 'Roar( Aberdeen, NC 28315 County of .Moore September 9, 2011 Jerry Ritter Thermal Metal Treating, Inc 9546 Hwy 211E PO Box 367 Aberdeen, NC 28315 Subject: NOTICE OF VIOLATION Permit No. A008 Dear Mr. Ritter: (910) 281-3146- Phone (910) 281-204.7- .fax A review of Thermal Metal's monitoring data for August 2011 showed the following violation(s): Parameter Date Limit Value Reported Value From Industry Reported Value From POTW Limit Type Nickel 8/4/11 3.98 mg/1 10.6 mg/1 Daily Maximum Exceeded Nickel 8/4/11 2.00 mg/1 5.622 mg/1 Monthly Average Av9- s+ Exceeded Additional testing was performed but the monthly average was not met. Per Section 8.1 of the Moore County Sewer Use Ordinance, Thermal Metal Treating shall respond in writing within thirty (30) days as to the cause of these violations and what corrective actions will be taken to prevent future violations. If you have any questions, please contact me at 910-281-3146. Sincerely, COW -EL Athen.-enJ Janna Scherer, County of Moore, Pretreatment Coordinator Cc: Mr. George Yankay, County of Moore, Superintendent Mr. Randy Gould, County of Moore, Public Works Director