NC0037508_Pretreatment Inspection_20061009

VVH;J.`l`" Michael F. Easley, Governor
October 9, 2006
James Delmo Frye
Operator in Responsible Charge (ORC)
1094 Addor Road
Aberdeen,NC 28315
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
SUBJECT: Pretreatment Compliance Inspection
Moore County Water Pollution Control Plant
NPDES Permit No. NC0037508
Moore County
Dear Mr. Frye:
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the
inspection conducted on October 5, 2006 with Stephanie Brixley, Pretreatment Coordinator. The
report indicates that Moore County Water Pollution Control Plant meets the pretreatment
requirements: as outlined in 15A NCAC 2H .0900 for the Pretreatment Programs. Please' send this
office a written response by December 13, 2006 concerning the following requirements that resulted
from the Pinnacle Furnishings, Inc. site inspection; this is in conjunction with your requirements that
were addressed in the October 6, 2006 Annual Inspection Review letter from the POTW to Pinnacle
Furnishings, Inc.
1. To prevent release of a major spill to the environment, adequate, spill containment must be
constructed and maintained. Wood is not adequate material for containment, as observed
by this inspection. If .spill containment leaks, then it does not satisfy the definition of
containment. For additional information, please see #1 in the Industrial Inspection
Comments of this report.
2. Concerning the missing pH calibration log since July 2006, the SIU permit states, in part,
that: "The permittee shall retain records of all monitoring information, including all
_ calibration and maintenance records...". Part II, 11.
3. - Concerning the calibration of the pH meter, the SIU permit states, in part, that: "Test
procedures .for the analysis of pollutants shall be performed in accordance with the
techniques prescribed in 40 CFR part 136...". Part .II, 3. For additional information,
please see #3 in the Industrial Inspection Comments of this report.
4. The manhole cover may be in the open position only when discharging from the
equalization tank; it should not be opened for long periods of time. It should be closed
during a rain event.
o One
hCarolin
Na
�V�aturally
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet: ncwaterquality.org FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Mr. Frye
October 9, 2006
Page 2
We appreciate your co-operation and your continued efforts with the pretreatment program.
If you have any questions concerning this report, please do riot hesitate to contact me at (910) 433-
3312.
Dale Lopez
Environmental Specialist
Enclosure: , Pretreatment Compliance Inspection Report
EPA Water Compliance Inspection Report
cc: Deborah Gore, PERCS -Pretreatment Unit
Stephanie Brixley, Pretreatment Coordinator, Moore County WPCP

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: Stephanie Bixley .
3. Title(s): Laboratory Supervisor/Pretreatment Coordinator
4. Last Inspection Date: 08/18/05 Inspection Type (Circle One): PCI Audit
5, Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)?
6. Is POTW under an Order That Includes Pretreatment Conditions?
Order Type And Number: Are Milestone Dates Being Met? Yes / No
PCS CODING
Trans.Code Program NPDES Number MM/DD/YY Inspec.Type
J N I JNICIO 10[3171510181 10 /05 /06 1Pl
(DTIA) ., (TYPI) . •
7. Current Number of Significant Industrial Users (SIUs)?
8. Current Number of Categorical Industrial Users (CIUs)?
9. Number of SIUs Not Inspected by POTW in the Last Calendar Year?
Both have been performed for the year
10. Number of SIUs Not Sampled by POTW in the Last Calendar Year?
11. Enter the Higher Number of 9 or 10.
12. Number of SIUs With No IUP or With an Expired IUP?
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).
14. Number of SIUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods.
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?
If Yes, What are the parameters and how are these problems being addressed?
Whole Effluent Toxicity failure in June 2006 was attributed to overdosing the dechlor, andl
18. has now been corrected
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?
Inspector
(INSP)
Yes
/ No
Yes /
No
Fac.Type
111
(FACC)
2
2
0
0
0
0
0
0
0
0
SIDS
CIUS
NOIN
NOCM
PSNC
MSNC
SNPS
Yes
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
No
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)
11/04/05
11/01/10
Industrial Waste Survey (IWS)
03/19/04
09/01/08
Sewer Use Ordinance(SUO)
10/07/97
07/01/07
Enforcement Response Plan (ERP) .
04/27/98
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
'No
'Yes
Yes

INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26.
User Name
Erico '
Pinnacle
27.
IUP Number
A005
A007
28.
Does File Contain Current Permit? -
Yes
Issued 07/31/03
Yes
Issued 07/31/03
29.
Permit Expiration Date?
06/30/08
06/30/07
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
12/30/02
Yes
05/24/06
32.
Does the File Contain an Inspection Completed Within Last Calendar
Year?
Yes
10/03/06
Yes
10/05/06
33.
a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a.Yes
rev. 03/15/05
b. N/A
Yes
a.
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,
rev. 12/03/04
b. Yes
Yes 08/30/06
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
The SIU is sampled monthly by the POTW
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
(water meter)
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
Yes
41.
a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations
b. Did Industry Resample Within 30 Days?
No Violations
For this year.
N/A
a. Yes
b. Yes
42.
Was the SIU Promptly Notified of any Violations (Per ERP)?
N/A
Yes
43.
During the Most Recent Semi -Annual Period, Was the SIU in SNC?
No
No

44.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
N/A
Yes
45.
Does the File Contain Penalty Assessment Notices?
N/A
No
46.
Does the File Contain Proof of Penalty Collection?
N/A
No
47.
a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
N/A
N/A
No
N/A
48.
Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
No
No
FILE REVIEW COMMENTS
The POTW records and files were well maintained:
PCI SUMMARY AND COMMENTS
Industrial Inspection Comments (Pinnacle Furnishings, Inc., IUP --- A007):
1) At least three sections of the 2 x 4 inch wood containment boards showed signs of warping to such a degree
that they did not exhibit the ability to retain a liquid spill.
2) The calibration log for the effluent pH meter could not be located. The last entry into the calibration log
was during July 2006. Please note that this meter was routinely used for pH testing of the industry's
process control.
3) The instruction manual for the pH meter could not be located in order to answer the question of how to
calibrate the pH meter. The label on the back of the pH meter describes the meter as a one -point and two -
point calibration type. This differed from the operator's procedure, as he said that he routinely performed
a three-point calibration of the pH meter.
Requirements: (Concerning the Industrial Inspection Comments (Pinnacle Furnishings, Inc., IUP --- A007)
1) To prevent release of a major spill to the environment, adequate spill containment must be constructed and
maintained: Wood is not adequate material for containment, as observed during this inspection (see #1
in the Industrial Inspection Comments, above). If spill containment leaks, then it does not satisfy the
definition of containment.
2) Concerning the missing pH calibration log since July 2006, the SIU permit states, in part, that: "The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records...". Part II, 11.
3) Concerning the calibration of the pH meter, the SIU permit states, in part, that: "Test procedures for the
analysis of pollutants shall be performed in accordance with the techniques prescribed in 40 CFR part
136...". Part II, 3.
4) The manhole cover may be in the open position only when discharging from the
equalization tank; it should not be opened for long periods of time. It should be closed
during a rain event.
PCI Comments:
1. Gulistan Carpet Corp. Textile, Ingersoll-Rand, and Kainos Technologies are on local permits.
2. In the future, Thermal Metals will fill out the long form (with application) and begin discharging to the
POTW. They will probably be treated as a CIU (since they perform a phosphoric acid dip in their
process).
3. The POTW sends all of its outside testing to Meritech.
4. Erico sends all of its outside testing to Carolina Environmental.

NOD:
NOV:
QNCR:
NO
INO
IrTO
POTW Rating:
Satisfactory ✓ Marginal Unsa
PCI COMPLETED BY: Dale Lopez, Environmental Specialist ;,
Name and Signature of Reviewer Agency/Office/Telephone
Belinda S. Henson
-�• �naor�
NCDENR/Fayetteville/(9 1 0) 486-1541
Date
/ 0/13/o

INDUSTRY INSPECTION CODING;
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
1 NI CIO 1013171510I81 10 /05/ 06 U J S J f_2J
(DTIA) (TYPI) (INSP) (FACC)
1.Industry Inspected: Pinnacle Furnishings Inc.
2.Industry Address: 10570 NC Hwy 211 E. Aberdeen, NC 28315
3.Type of Industry/Product: Manufacturing /Casino Furniture
4.Industry Contact: Jeff Turner Title: Plant Manager
Orlando Malave' `Title: Anodizing/Metal Dept.
Phone: 910- Fax: 910-
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 4
C. Pretreatment Tour J
D. Sampling Review
E. Exit Interview '1
Industrial Inspection Comments:
1) At least three sections of the 2 x 4 inch wood containment boards showed signs of warping to such a degree
that they did not exhibit the ability to retain a liquid spill.
2) ..The calibration log for the effluent pH meter could not be located. The last entry into the calibration log
was during July 2006. Please note that this meter was routinely used for pH testing of the industry's
process control. •
-
3) The instruction manual for the pH meter could not be located in order to answer the question of how to
calibrate the pH meter. On the back pH meter unit, the description was that the meter was a'one-point and
two -point calibration type. This differed from the operator's procedure, as he said that he routinely
performed a three-point calibration of the pH meter.

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 (Le., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 I NI 2 1 51 31 NC0037508 1 11 121 06/10/05 1 17
Type Inspector. Fac Type
181 1>1 191 g I . 20I 11
Remarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 2.0 1 69 701 31 71 11 721 N I 731 1 174 751 1 1 1 1 1 1 1"
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
10:30 AM 06/10/05
Permit Effective Date
05/07/01
Exit Time/Date
03:00PM 06/10/05
Permit Expiration Date
09/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
James Delmo Frye/ORC/910-281-3146/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Mi.chae.l. Hoiden, PO Box 905 Carthage NC 28327//910-947-6403 /
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 d Signature(s) of Insp Agency/Office/Phone and Fax Numbers
Dale Lopez ' FRO WQ//910-433-3300 Ext.712/
Date
l
!!!/// 6
Siignny�ature of Management Q0A Reviewer Agency/Office/Phone and Fax Numbers Date
-LaU
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NC0037508
NPDES yr/mo/day Inspection Type
11 121 06/10/05 .I 17 18
II
(cont.)
Section:D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Thermal Metals will become a CIU in the future. It will soon fill out the IWS long form and PT.application.
The POTW pretreatment records and files were well maintained. The annual pretreatment inspection of
Pinnacle Furnishings (a CIU) revealed that the containment walls around the 24 chemical and rinse tote
containers were not sufficient to contain a liquid spillin the event of a spill. •. Also, pH calibration records
were not well maintained. There was question that the correct manufacturer's pH calibration procedure
was not being followed. The pH instruction manual could not be located during the inspection.
Page# 2

Department of Public Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
Waaotty a/ Plioaxe
December 11, 2006
Telephone: [phone]
Facsimile: [phone]
Mr. Dale Lopez
DWQ/DENR DEAR----FR
225 Green Street, Suite 714
Fayetteville, NC 28301-5043 bEC 13100s
Re: Pretreatment Annual Inspection Response DWQ
Moore County Water Pollution Control Plant
NPDES Permit No. NC0037508
Moore County
Dear Mr. Lopez:
This letter is in response to the requirements set forth following the Pretreatment Annual
Inspection. The inspection was conducted at Moore County WPCP on October 5, 2006
and an on -site inspection at Pinnacle Furnishings, Inc followed on October 5, 2006.
A follow up inspection at Pinnacle Furnishings, Inc was conducted by Jeff Corder, Lead
Operator, and Janna Scherer, Pretreatment Coordinator, on December 4, 2006 and again
on December 8, 2006. The following is an explanation of what was found.
1. The wood containment wall, which was not adequately containing all spillage
from the anodizing line, has been replaced by a permanent brick wall. The
wall measures three inches high on all sides and six inches high on both ends
taking into account the slope of the floor. The bricks are mortared to the floor,
to one another, and completely encased in concrete. The new wall will
adequately contain any spillage and will be inspected routinely for any signs
of defect.
2. On the December 4 visit, there was no progress on the pH calibration or,
operation log. As of the December 8 visit, a calibration log has been
established and the pH meter is being calibrated correctly daily with a 2-point
calibration and a buffer check. The instruction manual for the meter is located
in the log book. New buffers have been ordered and Pinnacle's management is
discussing ordering a new meter. Sampling procedures and correct record

Department of Public Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
Woamty a/ alooxe
Telephone: [phone]
Facsimile: [phone]
keeping procedures were explained and will continue to be checked during
visits.
3. On numerous visits following the Annual Inspection, the manhole cover has
been in the closed position prior to discharge. This issue has been sufficiently
resolved.
4. All the tanks are labeled as of the December 8 visit to Pinnacle.
Pinnacle Furnishings, Inc has been cooperative in completing the requirements set forth
by the Moore County WPCP. They will be monitored to prove continued compliance.
Please contact me with any questions or concerns at [phone].
Sincerely
Janna L. Scherer, Lab Supervisor/Pretreatment Coordinator, Moore County WPCP
Cc: Mr. Marcus Jones, Director, Moore County Public Works
Mr. James Frye, Superintendent, Moore County WPCP
Ms. Deborah Gore, DWQ PERCS Unit
Mr. Dale Lopez, Inspector, DWQ Fayetteville Regional Office