NC0035708_Pretreatment Compliance Inspection_20090112

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CO 7
Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
January 12, 2009
Janna Scherer
Pretreatment Coordinator/Lab Supervisor
1094 Addor Road
Aberdeen, NC 28315
SUBJECT: Pretreatment Compliance Inspection
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 December 17, 2008 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. 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 [phone].
Dale Lopez
Environmental Speciaa
Enclosure: Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
Theinial Metal Treating, Inc. enforcement infouiiation, (six pages)
2009 TTO Certification Check Sheet
cc: Dana Folley, PERCS -Pretreatment Unit
FRO files
One
NorthCarotina
Naturally
North Carolina Division of Water Quality 225 Green Street, Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Fax [phone]
Internet: www.ncwaterqualitv.org
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
FAYETTEVILLE REGIONAL OFFICE
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: Moore County Water Pollution Control Plant
2. Control Authority Representative: Janna Scherer
3. Title(s): Laboratory Supervisor/Pretreatment Coordinator
4. Last Inspection Date: 01/10/2008 Inspection Type (Circle One): PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? Yesl
6. Is POTW under an Order That Includes Pretreatment Conditions? Nol
Order Type And Number: Are Milestone. Dates Being Met? Yes / No
PCS CODING
Trans.Code Program NPDES Number MM/DD/YY
�I J NI CIO 10 13.17 15 10 18 12 /17 /09
(DTIA)
Inspec.Type Inspector
IPI JSIIII
(TYPI) (INSP)
Fac.Type
(FACC)
7. Current Number of Significant Industrial Users (SIUs)?
4
SIUS
8. Current Number of Categorical Industrial Users (CIUs)?
4
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
NOCIv
13. Number of SlUs 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?
If Yes, How Are These Problems Being Addressed?
No

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? (May refer to PAR if Excessive SIUs in SNC)
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?
SNC for Limits: 0
SNC for Reporting: 0
Not Published: 0
0
PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable
11/04/05
11/01/10
Headwork Analysis (HWA)
Industrial Waste Survey (IWS)
11/05/08
09/01/13
Sewer Use Ordinance (SUO)
10/16/07
Enforcement Response Plan (ERP)
11/19/08
Long Term Monitoring Plan (LTMP)
07/13/04
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies?
23. Should any Pollutants of Concern be Eliminated From or Added to the LTMP?
24. Are Correct Detection Levels being used for all LTMP Monitoring?
25. Is the LTMP Data Maintained in a Table or Equivalent?
Yes
Is the Table Adequate?
[Yes
Noj
Yes
[Yes

INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26. User Name
Thermal Metals
Erico
27. IUP Number
A008
II A005
28. Does File Contain Current Permit?
Yes
Issued 07/01/08
Yes •
Issued 07/01/08
29. Permit Expiration Date?
06/30/10
06/30/13
30.
Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
433
433
31. Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
Yes
12/28/07
Yes
12/20/07
32. Does the File Contain an Inspection Completed Within Last Calendar
Year?
Yes
12/03/08
Yes
11/25/08
~ 33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Fonn from POTW)
Yes
Yes
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
Yes
Yes
35. ' a. Does the File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes, 07/03/08
b. Yes
a. Yes, 07/03/08
b. Yes
36. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP?
yes
Yes
37. Does File Contain POTW Sampling Chain -Of -Custody's?
Yes
Yes
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required By IUP?•
Yes
Yes
39. Does Sampling Indicate Flow or Production?
Yes
Yes, (Continuous
Discharge)
SIU sends POTW a monthly sheet with the daily flows
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Yes, Violations in
Feb & Mar 2008
N/A
No Non -Compliance
41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations
b. Did Industry Resample Within 30 Days?
a. Yes
b. Yes
N/A
N/A
42. Was the SIU Promptly Notified of any Violations (Per ERP)?
Yes
N/A
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
No
N/A
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
Yes
(see attached copies)
N/A
45. Do the Files Contain Penalty Assessment Notices?
N/A
N/A

46. Does the File Contain Proof of Penalty Collection?
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
48. Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
N/A
N/A
N/A
N/A
No
No
FILE REVIEW COMMENTS
1. Erico was the only CIU/SIU that owns a 24-hour composite sampler. They were also the only one that
had 24-hour discharge. The flow was measured with an ISCO 3010 Ultrasonic Flow Meter.
2. Thermal Metals performed batch discharge. Samples were dipped out of the discharge of the flocculation
tank.
3. Meridian used an 8.5 gallon per discharge with an automatic transfer pump with counter.
4. An oversight by the PT Coordinator delayed the sending a Non -Compliance to Thermal Metals for not
reporting the TTO Certification letter for the first half of 2008. Please see the attached Notice of Non -
Compliance that was sent to, Thermal Metals, the TTO Certification letter sent by Thermal Metals, and a
TTO check sheet for the PT Coordinator to monitor the TTO Certification letters from the four CIUs
(433).
5. An attachment to this PCI includes the Notice of Violations that were sent to Thermal Metals for the
February and March 2008 IUP limit exceedances. The Response Letter from the Thermal Metals, for the
February 2008 NOV, is also included.
PCI Comments:
1. The POTW records and files were organized and well maintained.
NOD:
NOV:
QNCR:
NO
NO
NO
POTW Rating:
Satisfactory ✓ Marginal
nsatisfactory
PCI COMPLETED BY: Dale Lopez, Envi a} pecfii t Date: 01/12/2009
Name and Signature of Reviewer Agency/Office/Telephone Date
Belinda S. Henson n " v NCDENR/Fayetteville/[phone]
`401

INO INDUSTRY INSPECTION PERFORMED DURING THIS PCI
INDUSTRY INSPECTION CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
J NI CIO 10 13171510181
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4.Industry Contact:
00 /00 / 00 J I I I .S I
(DTIA) (TYPI) (INSP) (FACC)
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:

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 I NI "2 151 31 N00037508 111 121 08/12/17 1 17
Type Inspector Fac Type
181 p1 191 s1 201 1
I I I I 1 1 1 1 1 1 I "I I I 1166
Remarks
211 I I 1 I I I I 1 I I 1 I 1 1 1 I I I I 1 1.1 1 1 1 1 I I► I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 2.0 1 69 7° 1 41 71 11 721 NI 731 1 1 74 751 I I I I I 1 J 80
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
1060 Addor Rd
Aberdeen NC 28315
Entry Time/Date
10:00 AM 08/12/17
Permit Effective Date
05/07/01
Exit Time/Date
02:00 PM 08/12/17
Permit Expiration Date
09/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Jeffery W Corder/ORC/910-281-3146/
Other Facility Data
,
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Marcus A Jones,PO Box 1927 Carthage NC 28327/Public Works Director//
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
131 Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspectors) ) Agency/Office/Phone and Fax Numbers Date
!
Dale Lope FRO WQ//910-433-3300 Ext.712/ /y
Signature of Ma agement Q A Re iewer Agency/office/Phone and Fax Numbers Date
, 1404idc-YD 1/'2/U9
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES
NC0037508
111 121
yr/mo/day
08/12/17
Inspection Type
17 18IPI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(1) Erico was the only CIU/SIU that owns a 24-hour composite sampler. They were also the only one that
had continuous 24-hour discharge. The flow was measured with an ISCO 3010 Ultrasonic Flow Meter. (2)
Thermal Metals performed batch discharge. Samples were dipped outofthe discharge of the flocculation
tank. (3) Meridian used an 8.5 gallon per discharge with an automatic transfer pump with counter. (4) An
oversight by the PT Coordinator delayed the sending of a Non -Compliance to Thermal Metals for not
reporting the TTO Certification letter for the first half of 2008. Please see the attached .Notice of
Non -Compliance that was sent to Thermal Metals, the TTO Certification letter sent by Thermal Metals, and
the TTO check sheet for the PT Coordinator to monitor the TTO Certification letters for the four ClUs (433).
(5) An attachment to this PCI includes the.NOVs that were sent to Thermal Metals for the February and
March 2008 IUP limit exceedances. The Response Letter from Thermal Metals, for the February 2008
NOV, is also included.
Page # 2

Department of Public Works,
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
Woiplay
March 24, 2008
Jerry Ritter
Thermal Metal Treating, Inc
9546 Hwy 21 I E •
PO Box 367
Aberdeen, NC 28315
Subject: NOTICE OF VIOLATION
Permit No. A008
Dear Mr. Ritter:
.Telephone: (930) 281 •-3 11(5
Facsimile: (9.10) 28 1 -20 1 7
LY
A review of Thermal Metal Treating's monitoring data for February 2008 showed the following
violation(s):
Parameter
Date
Limit
Value
Reported
Value
From Industry
Reported
Value From
POTW
Limit Type
Copper
2/14/08.
2.07 mg/1
2.98 mg/1
Monthly Average
Exceeded
Nickel
2/14/08
3.98 mg/1
. 41.2 mg/1
Daily Maximum
Exceeded
Nickel
2/14/08
2.00 mg/1
41.2 mg/1
Monthly Average
Exceeded
Zinc
2/1.4/08
2.61 mg/1
8.43 mg/1
Daily Maximum
Exceeded
Zinc
2/14/08
1.48 mg/1
8.43 mg/1
Monthly Average
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.
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 reporting violations.

A9443
TFIERMiAL METAL TREATING, INC.
Your gateway to innovative metal processing technology
ISO 9002
April 21, 2008
Janna Scherer
Moore County
Waste Water Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
Subject: Notice of violation reply
Permit No. A008
Dear Janna Sherer,
9546 HWY 211 EAST - ABERDEEN, NC 28315
PO BOX 367 - ABERDEEN, NC 28315
P: 910 — 944 -3636
F: 910 — 944 -3280
www.thermalmetal.com
APR 2 d 2008 AJJ
BY:
Thermal Metal Treating was sited for exceeding its daily and monthly maximum discharge
limits for Nickel and Zinc and the daily limit for copper during its last reporting cycle.
Regarding the violation of its waste water permit the following is the response for corrective
action:
o Identified the waste stream within the facility that contributed to the violation
• Set up an independent reservoir to segregate this waste stream
• Batch -treat and test for metals separately from the other waste streams.
o Improved our in house metal test procedures to evaluate lower mg/liter quantities.
Attached please find the last independent laboratory metal test result of the TMT treated
waste stream.
Best regards,
Jry Ritter
resident

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: David Wilson
Client: 'ii'hermal Metal Trea ting, Inc.
PO Box 367
Aberdeen, NC 2831.5
iMeritech Work Order it 03270842
Sample: Pipe 01 Grab
Report Date:
Date Sample Rcvd:
Parameters Result
Analysis Date Reporting Limit Method
Cadmium, total < 0.002 mg/L . 4
(_hro.mium, total /3/08 0.002 mg/L . EPA 200.7
0.025 mg/L 4/3/08 0.005 mg/L EPA Copper, total 0.144 ill L g/ EI-A 200.7
Lead, toted g/ 4/3/08 0.002 mg/L E.I'A 200.7
< 0.010 uig/L 4/3/08
Nickel, total 0.423 mg/L0.010 mg/L EPA 200.7
Silver, total 4/3/08 0.010 mg/L EPA 200.7
4/3/08
< 0.005 mg/L 4/3/08 0.005 mn L
Zinc, total 0.370 .m.g/L g/ EPA 200.7Cyanide, total 0.01.0 mg/L EPA 200.7
<0.005 m L
pH 9.8 mgS.U/ 3 27/ 08 0.005 mg/L EPA 335.4
/ 1.0 - 14.0 S.U. SM 4500 I -I B
4/4/08
3/27/08
3/27/08
.1 hereby certify that.I have reviewed and approve these data.
aborator.V Representative
642 Tanuo Road, Reidsville, North Carolina 27320
t el. [phone] fax.[phone]

Department of Public Works
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
April 28, 2008
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:
Telephone: [phone] ,16
Facsimile: [phone]
A review of Themal Metal Treating's monitoring data for March 2008 showed the following
violation(s):
Parameter Date
Copper
Copper
Zinc
Zinc
3/13/08
Limit
Value
3.38 mg/1
Reported
Value
From Industry
5.14 mg/1
Reported
Value From
POTW
March
2.07 mg/1
2.64 mg/1
3/13/08
2.61 mg/1
3.71 mg/1
Limit Type
Daily Maximum
Exceeded
Monthly Average
Exceeded
March
1.48 mg/1
2.04 mg/1
Daily Maximum
Exceeded
Monthly Average
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.
Additional samples were collected by Thermal Metal Treating and sent out for testing. Results
showed that the problems had been corrected but monthly averages were not within the permitted
limits. No response is needed at this time. Please be aware of your permit limits.
If you have any questions, please contact me at 910-281-3146.

rrrl tL YI L. Li _I
Department; of Public Works
Wastewater Treatment Plant
1.094 Addor Road
Aberdeen, NC 28315
•As
� ageOtty
December 29, 2008
Jerry Ritter
Thermal Metal Treating, Inc.
9546 NC 211 E
PO Box 367
Aberdeen, .NC 28315
Subject: NOTICE OF NON-COIVIPLIANCE
Permit No. A008
Telepb.one: (91.0) 281-31.46
Facsimilef [phone]
Dear Mr. Ritter:
A. review of the Thermal Metal Treating files for 2008 showed the following violation(s):
Parameter Date Limit Value Reported Limit Type
Reporting
Jamiary i —
June 30
Value
From Industry
No TTO
Certification
Reporting
Vidlations-
Incomplete
Report
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.
The violation was discussed during the annual inspection and a report was received on
December I8, 2008. Please note Part I1_l, 7 (Total Toxic Organics Certification) in your
permit regarding due dates and requirements for TTO certification.
If you have any questions, please contact me at 910-281-31.46.
Sincerely,
C 1dcuytiyia 2
Janna Scherer, County of Moore, Lab Supervisor/Pretreatment Coordinator
Cc: Mr. James D. Frye, County of Moore, Superintendent
Mr. Dennis Brobst, County of Moore, Public Works Director

A9443
THER E'; L METAL TREATING, INC.
Your gateway to innovative metal processing technology
ISO 9002
TO: Moore County Water Pollution
Control Plant
1094 Addor Road
Aberdeen, NC 28315
9546 HWY 211 EAST - ABERDEEN, NC 28315
PO 90X 367 , ABERDEEN, NC 28315
P: 910 - 944 -3636
F: 910 - 444 -3280
www.thermalmeta I.com
MgMEVErm
DEC 1 `.b 2008
B Y: a�
TTh:Jenny Scherer Januarylst — June 30th 2008
Pretreatment & FOG Coordinator REF: TTO (Total Toxic Organic)
Thermal Metal Treating believes and substantiated by the small levels detected by the lab
analysis that these toxic organics will remain at the low levels listed in the Total Toxic
Organic (TTO) test panel. .
Thermal Metal also certifies that:
"Based on my inquiry of the person or persons directly responsible for managing
compliance with the permit limitation (or pretreatment standard) for total toxic
organic (TTO), we certify that, to the best of our knowledge and belief, no dumping
of concentrated toxic organics into the wastewaters has occurred at our facility. We
further certify that Thermal Metal Treating is implementing the Toxic Organic
Management Plan submitted to the Moore County POTW_"
If any questions please feel free to contact Thermal Metal at 910-944-3636.
Sincerely,
Jerry Ritter
President

2009 TTO Certification Check Sheet
Jan 1 — June 30
July I — December 31
Industry
Date Received
Date Received
Erico
Pinnacle
Thermal Metal
Meridian Kiosks