Loading...
HomeMy WebLinkAboutNC0037508_Pretreatment Audit_20100813ATA, NCDENR North Carolina Department of Environment and Natural Resources Division of WaterQuality Beverly Eaves Perdue Coleen H. Sullins Governor Director August 13, 2010 Janna Scherer Pretreatment Coordinator/Lab Supervisor. 1094 Addor Road Aberdeen, NC 28315 SUBJECT: Pretreatment Audit Inspection Moore County Water Pollution Control Plant NPDES Permit No. NC0037508. Moore County Dear Ms. Scherer: Dee Freeman 'Secretary Enclosed you will find a copy of the Pretreatment Audit Inspection Report for the August 10, 2010 inspection of the pretreatment, records and files. An industrial inspection was conducted at Pinnacle furnishings, Inc on August 11, 2010 in which I met with you, Sherry Augustin (Office Manager), and Orlando Malave (Anodizing Line Operator). 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. My complements to you on an excellent job of up-to-date record keeping and organization of the. Pretreatment files. If you have any questions concerning this report, please do not hesitate to contact me at (910) 433-3312. (Dale Lopez Environmental Specialist Enclosure: Pretreatment Audit Inspection Report EPA Water Compliance Inspection Report cc: Dana Folley, PERCS -Pretreatment Unit FRO files .; 225 Green St., Suite 714, Fayetteville, NC 28301-5043 Phone: 910 '433-3300 l FAX: 910-486-07071 Customer Service`. 1-877-623-6748 Internet: www,ncwaterqualij'.crg One 1\ orthCaro]_ina An Equal Opportunity ; Affirmative Action Employer 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: Moore County WPCP 2. Control Authority Representative(s): Janna Scherer 3. Title(s): Chemist/PT Coordinator/FOG Coordinator 4. Address of POTW: Mailing: 1094 Addor Rd City Aberdeen Zip Code: 28315 Phone Number: 910-281-3146 Fax Number: 910-281-2047 E-Mail: jscherer(amoorecountync.gov 5. Audit Date 08/10/2010 6. Last Inspection Date: 12/17/2008 Inspection Type: ® PCI ❑ Audit 7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ►1 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. Moore County WPCP experienced toxicity problems in September 2009 and October 2009 which led to a failure for the quarter in November 2009. No reason for the failures was ever determined. The WPCP has not experienced any further problems (passed in December 2009, March 2010, and June 2010). The next test will be in September 2010. 9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No Parameters Covered Under Order PCS (WENDB) Coding Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type INICI0 I0 13 17 15 )0 18 I 108I10 I10I IGI Ls_J 11 (DTIA) (TYP1) (INSP) (FACC) 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 Last Calendar Year? 13. Number of SIUS Not Sampled by POTW in Last Calendar Year? 14. Enter Higher Number of 12 or 13 15. Number of SIUS in SNC for Either Reporting or Limits Violations During Either of Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 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 3 3 0 0 0 0 0 0 0 0 SIUS CIUS NOIN PSNC 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 PaaP. 1 21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element in their File, with all supporting documents and PERCS Approval Letter, and dates consistent with Program Info: Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable 11/1/10 Headworks Analysis (HWA) 11/2/05 /1 Yes ❑ No 11/4/05 ►Z1 Yes ❑ No Industrial Waste Survey (IWS) 8/22/08 // Yes ❑ No 11/5/08 /1 Yes ❑ No 9/1/13 Sewer Use Ordinance (SUO) 5/31/07 1/ Yes ❑ No 10/16/07 ►1 Yes ❑ No Enforcement Response Plan (ERP) 10/30/08 11 Yes ❑ No 11/19/08 /1 Yes ❑ No Long Term Monitoring Plan (LTMP) 6/24/04 11 Yes ❑ No 7/13/04 11 Yes ❑ No 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. Camp MacKall Army Base 23. If yes to #22, Do you have current lnterjurisdictional Agreements (IJAs) or other Contracts? /5 Yes ❑ No El NA A copy, if not already submitted, should be sent to Division. A copy of the contract was sent to the FRO with the response to the last pretreatment Audit in April 2004. 24. If yes to #22. Have you had any trouble working withthese towns or districts? ❑ Yes ® No ❑ NA If yes, explain. 25. Date of Last SUO Adoption by Local Council 5/21/2007 26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes If yes, explain. Enforcement (Enforcement Response Plan-ERP) 27. Did you send a copy of the ERP to your industries? /1 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 N/A Resources 30. Please Rate the Following: S=Satisfactory M=Marginal. U=Unsatisfacto Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program 11 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 /IS ❑M ❑U Reference Materials ►IS ❑M ❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) ►1S ❑M ❑U Computer Equipment (Hardware and Software) /5S ❑M ❑U North Carolina Pretreatment Audit Form PP OP. 7 31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. All data related to the pretreatment program is organized into Excel spreadsheets. LTMP data and industry results and flows are entered monthly or accordingly. 32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Costs are recovered through sampling fees charged to industries. No Surcharges and no IUP fees are charged to the SIUs. 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 4 No If yes, Explain procedure. If no, how would the request be addressed? A request should be made in writing by the individual of what they would like to review. The request would be reviewed by the Pretreatment Coordinator and the WPCP Superintendent. Files would be available for review at a designated time and at the WPCP. A photocopy of the person's driver's license will be made. 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? A request would be made in writing by the SIU of what information they want confidential. This would exclude all data related to the effluent from the SIU. All pretreatment information is kept in a locked file cabinet. 36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? /Z4 Yes ❑ No 37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No Information can be found in the Board of Commissioners (BOC) meeting minutes. 38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No No industries in SNC. Permitting (Industrial Waste Survey-IWS) 39a...How does the POTW become aware of new or changed Users? The IWS is completed every 5 years but short forms are sent to all new industries which may be found in the local news paper or on the Board of Commissioners agenda. If an industry contacts the county, they are notified to contact the Pretreatment Coordinator at the WPCP. 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?) As much information is obtained as possible through a short form and a long form survey, if necessary, a site visit is performed, categorical classification is judged, an estimated flow is determined, sampling is performed for a period of time if permitting is not required. An SIU is >25,000 GPD, meets categorical standards, a threat to the WPCP or 5% MAHL. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? Yes No If Yes, How many are there? 1- Transfer Station Please list each site and how it is permitted, if applicable. No current permit. 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: designated point, samples drawn, manifests required) Each truck load is sampled for a pH and visually inspected by a WPCP representative, a manifest must be filled out by the hauler and signed by a WPCP representative, and the waste must be dumped at the designated location during the designated hours. Haulers are permitted annually to dump at the WPCP. 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: 44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ►1 No If yes, what parameters are over allocated? North Carolina Pretreatment Audit Form Paae. 1 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? ® Yes ❑ No If yes, what percentage of each parameter >75% presently, and no lower than 10% 47. Has the POTW experienced any difficulty in allocation? (For example: adjudication by an industry) ❑ Yes I 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) All current SIUs have 433 categorical parameters. Other permit limits are determined through historical data and industry need. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Industries are sampled at a frequency that reflects their production and flow. Erico has continuous flow and is sampled monthly. Thermal Metal and Pinnacle are batch dischargers and are sampled on a quarterly sampling schedule with Annual and Bi-Annual samples collected during the year as well (6 months). Permit Compliance 50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes PJ 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. Compliance is judged using the ERP for Moore County. If follow up testing is possible, it is conducted ASAP. NOVs are mailed within 30 days of initial findings. SNC is judged throughout the year to determine if an industry is in danger of being SNC. Extra testing may be conducted to avoid SNC. If an industry is SNC, it is published in the local news paper. 52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, 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? All SIUs are required to have one. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Plans should contain POTW contact information, procedures of which to follow in the case of an accidental spill or slug, notification procedures and have MSDSs on file. Plans are reviewed annually during the SIU inspection. The phone contact lists are reviewed annually. 56. How does the POTW decide where the sample point for an SIU should be located? The sample point is located where all effluent from the pretreatment units is mixed prior to discharge into the collections system. For batch discharges, industries collect from the batch tank prior to discharge into the collections system. 57. Has 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 SIU: ® Yes ❑ No If yes, Explain. The current sampling locations are used by the WPCP as well as the SIUs and their representative commercial labs. SIU representatives handle all samples and mix prior to collection in the WPCP sample jug. It is then signed over to the WPCP representative. Erico has 24-hour composite sampling, and Thermal Metals and Pinnacle perform grab sampling on batch discharge. 58. Who performs sample analysis for the POTW for Metals Mertiech Conventional Parameters Meritech and Moore County WPCP Organics Meritech 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. In house, samples are collected by POTW operators. Samples are signed over to the lab by the operator who collected the sample when samples are delivered. Each COC contains sample location, ID number, date, time collected, collectors initials, type of sample (C or G), tests to be performed, and temperature (if applicable), collectors signature, time relinquished, date North Carolina Pretreatment Audit Form Pacer. d relinquished, receivers signature, time received and date received. Commercial lab samples follow the same custody procedures. We use Meritech's COC and fill it out with the appropriate information. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA) 60a. Is L/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ►Z/ YES ❑ NO 60b. Are Correct Detection Levels being used for all L/STMP Monitoring? ❑ YES ® NO Total Nitrogen and Total Phosphorus have lower detection limits (0.2mg/L) than stated in the LTMP (0.5mg/L). The Ammonia detection level for the meter used at the WPCP is 0.5mg/L which is higher than the 0.1mg/L stated in the LTMP. , 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 yourselfl 60e. If NO to any above, list violations 60f. Should any Pollutants of Concern be Eliminated from or Added to L/STMP? ❑ YES A. 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? ►1 Yes ❑ No If yes, what is the reason for the revision? (Mark all that apply) ❑Increased average flow ®NPDES limits change More LTMP data available ❑Resolve over allocation ►15 year expiration ❑ Other Explain. HWA is due in November 2010. WPCP will be upgraded and expanded in the next few years and permit limits will change. 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? The plant will be upgraded in the future (we are in the planning stage now) to 10 MGD. North Carolina Pretreatment Audit Form Paor. 5 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 TUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 66. User Name 1. Pinnacle Erico Thermal Metals 67. IUP Number A007 A005 A008 68. Does File Contain Current Permit? /1 Yes ❑ No Eff. 07/01/2010 1I1 Yes ❑ No Eff. 07/01/2008 ►I Yes ❑ No Eff. 07/01/2010 69. Permit Expiration Date 06/30/2015 06/30/2015 06/30/2015 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 40 CFR 433 40 CFR 433 40 CFR 433 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes ❑ No 12/15/2009 /i1 Yes ❑ No 12/20/2007 Yes ❑ No 12/24/2009 72. Does File Contain Inspection Completed Within Last Calendar Year? Yes ❑ No 12/08/09 ►1 Yes ❑ No 12/08/09 Yes ❑ No 12/10/09 73. a. Does File Contain Slug/Spill Control Plan? b. 1fNo, is One Needed? (See Inspection Form from POTW) a. _Yes •No b. ■Yes ■No a. @@Yes ■No b. •Yes ■No a. ►@Yes •No b. ■Yes ■No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? ®Yes❑No❑N/A 1s` half 2010 ®Yes❑No❑N/A 1st half 2010 ®Yes❑No❑N/A ls' half 2010 75. a. Does File Contain Original Permit Review Letter from Division? b. All Issues Resolved? a. @Yes •No 03/29/2010 b.®Yes❑No❑N/A a. _Yes ■No 07/03/2008 b.®Yes❑No❑N/A a. _Yes ■No 03/29/2010 b.®Yes❑No❑N/A 76. During Most Recent Semi -Annual Period, Did POTW Complete its Sampling as Required by IUP. including Flow? /i1 Yes ❑ No ►Z1 Yes ❑ No i1 Yes ❑ No 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ►'1 Yes ❑ No 1i1 Yes ❑ No i1 Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its Sampling as Required by IUP, including Flow? ®Yes❑No❑N/A ❑YesENo❑N/A See Comment #2, below ®Yes❑No❑N/A 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on time? ®Yes❑No❑N/A ❑YesENo❑N/A See Comment #2, below ®Yes❑No❑N/A 80a. For categorical Ilis with Combined Wastestream Formula (CWF). does file include process/dilution flows as Required by 1UP? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 80b. For categorical Ills with Production based limits, does file include production rates and/or flows as Required by IUP? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A 81. During Most Recent Semi -Annual Period, Did POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? i1 Yes ❑ No i1 Yes ❑ No /i1 Yes ❑ No none none none 82. During Most Recent Semi -Annual Period, Did POTW Identify All Reporting Non -Compliance from SIU Sampling? Yes ❑ No ' Yes ❑ No Yes ❑ No none none 83. a. Was POTW Notified by S1U (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 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 84. During Most Recent Semi -Annual Period, Was SIU in SNC? ❑ Yes No ❑ Yes /i1 No ❑ Yes No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in POTW's ERP? . ❑Yes❑NoEN/A ❑Yes❑NoEIN/A ❑Yes❑NoEIN/A 86. Does File Contain Penalty Assessment Notices? ❑YesENo❑N/A ❑YesENo❑N/A ❑Yes _+No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑YesENo❑N/A ❑YesENo❑N/A ❑YesENo❑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 a.❑Yes❑No®N/A b.❑Yes❑No❑N/A a.❑Yes❑No®N/A b.❑Yes❑No❑N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested Information For You? ❑ Yes ►i1 No ❑ Yes ►i1 No ❑ Yes 1'1 No FILE REVIEW COMMENTS: 1. The files appeared complete, in good order, and very well maintained. 2. (Please see #78 & #79, above) Due to oversight after a recent change in pretreatment personnel at Erico, the single four -day sampling event for the first half of 2010 was missed. The results were due to the POTW by July 15, 2010. The four "re"samples were taken on July 6 thru July 9. On July 14, the POTW sent an NOV to Erico. The POTW received the chemistry results on August 9, 2010. Erico was not in SNC for late reporting because the self -monitoring reports were received within 30 days following the due date. North Carolina Pretreatment Audit Form Pacer F. INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type LNJ INICI0101317I51018I I08I101101 It] I ISI I2 (DTIA) (TYPI) (INSP) (FACC) 1. Industry Inspected: Pinnacle Furnishings, Inc 2. Industry Address: 10570 NC Hwy 211 East, Aberdeen, NC 28315 3. Type of Industry/Product: Casino furniture 4. Industry Contact: Orlando Malave Title: Anodizing Line Operator Phone: (910) 944-0908 Fax: (910) 944-0920 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 4 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: High quality casino stools with aluminum bases are anodized, upholstered, and assembled at this facility. Pre -formed extruded aluminum pipes and other extruded items are purchased from an extrusion facility in Georgia. At the Pinnacle site, the pipes are cut, the aluminum is brushed, and the metal parts are processed through the chemical vats. Sodium Gluconate, Caustic Soda, Sulfuric Acid, Phosphoric Acid, Nitric Acid were some of the reagents that were in various vats. The periodic process discharges were to a 1550 gallon holding tank. The tank was discharged to manhole that flowed into the POTW collection system. FILE REVIEW COMMENTS: All files that were reviewed were in good order. Audit SUMMARY AND COMMENTS: Audit Comments: The files were very well maintained. Requirements: none Recommendations: none NOD: El Yes ® No NOV: ❑ Yes ® No QNCR: El Yes ® No POTW Rating: Satisfactor,® Marginalp,❑ Audit COMPLETED BY: Dale Lopez Reviewed by: Belinda Henson Unsatisfactory ❑ DATE: 08/13/2010 DATE: North Carolina Pretreatment Audit Form PaoP. 7 United States Environmental Protection Agency EPA 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 1111 2 151 31 NC0037508 111 121 10/08/10 117- Type Inspector Fac Type 18I CI 191 SI 201 I III66 Remarks 211I II 1111111111111111111111111111111111111'II Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved — 671 2.0 169 701 41 711 I 721 NI 731 1 1 74 751 1 1 1 1 1 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) Moore County WPCF 1094 Addor Rd Aberdeen NC 28315 Entry Time/Date 10:00 AM 10/08/10 Permit Effective Date 05/07/01 Exit Time/Date 04:00 PM 10/08/10 Permit Expiration Date 09/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jimmy Brant Sikes/ORC/910-948-2431/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Dennis L Brobst,PO Box 1927 Carthage NC 28327/Public Utilities Contacted Director/910-281-3146/9102812047 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) and`Sign`ature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Dale Lopez t� FRO WQ//910-433-3300 Ext.712/ '7 13 • Signature of Manag ment Q Pr. Reviewer Agency/Office/Phone and Fax Numbers Date g. / 62/1 b EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 31 NPDES NC0037508 111 121 yr/mo/day 10/08/10 Inspection Type 17 18I C (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 Audit Inspection Report for the August 10, 2010 inspection of the pretreatment records and files. Due to oversight after a recent change in pretreatment personnel at Erico, the single four -day sampling event for the first half of 2010 was missed. The results were due to the POTW by July 15, 2010. The four "re"samples were taken on July 6 thru July 9. On July 14, the POTW sent an NOV to Erico. The POTW received the chemistry results on August 9, 2010. Erico was not in SNC for late reporting because the self -monitoring reports were received within 30 days following the due date. 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. My complements to you on an excellent job of up-to-date record keeping and organization of the Pretreatment files. Page # 2