NC0037508_Pretreatment Inspection_20041021

NCIEP:.R
North Carolina Department of Environment and Natural. Resources
Michael F: Easley, Governor
October 21, 2004
• Phillip Boles.
• Moore County Public Works Director
P.O. Box 756
Carthage, NC 28327
SUBJECT: . Pretreatment Compliance Inspection
Moore County Water Pollution Control Plant
NPDES Permit No. NC0037508
Moore County
William G. Ross Jr:, Secretary
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
Dear Mr. Boles:
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the inspection
conducted on September 8, 2004. 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.
The report is self-explanatory and contains observations and recommendations. We appreciate the co-
operation of Stephanie Brixley, Pretreatment Coordinator.
This 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 [phone].
Sincerely,
Dale Lopez
Environmental Specialist
/dl
Enclosure: Pretreatment Compliance Inspection Report
cc: Stephanie Brixley, Pretreatment Coordinator, Moore County WPCP
Jon Risgaard, DWQ Pretreatment Unit
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] FAX: [phone] Internet: www:enr.state.nc.us/ENR/
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
NorthCarolina
Naturally

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: 04/14/04 Inspection Type (Circle One): PCI
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
Audit
PCS CODING
Trans.Code
Nl
Program NPDES Number
J NI CI,O 10 13 17 15 10 18 1
MM/DD/YY
09 / 08 / 04
(DTIA)
Inspec.Type
JPl
(TYPI)
Inspector
ISI
(INSP)
IYes
/ No
Yes /
No
Fac.Type
J11
(FACC)
7. Current Number of Significant Industrial Users (SIUs)?
1
SIUS
8. Current Number of Categorical Industrial Users (ClUs)?
1
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?
No
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:
SNC for Reporting:
Not Published:
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)
10/06/03
04/01/08
Industrial Waste Survey (IWS)
03/16/04
09/01/08
Sewer Use Ordinance (SUO)
10/07/97
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?
1Yes
Is the Table Adequate?
Yes
No
Yes
IYes

AL USER PERMIT (UP) FILE REVIEW
26.
User Name
Erico
27.
IUP Number
A005
28.
Does File Contain Current Permit?
Yes
Issued 07/31/03
29.
Permit Expiration Date?
06/30/08
30.
Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
413
31.
Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
Yes
12/30/02
32.
Does the File Contain an Inspection Completed Within Last Calendar
Year?
Yes
04/06/04
33.
a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a.Yes
rev. 02/10/99
b. N/A
a.
34.
For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
Yes
35.
a. Does the File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a.Yes, 09/17/03
b. Yes
36.
During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP?
Yes
37.
Does File Contain POTW Sampling Chain -Of -Custody's?
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
39.
Does Sampling Indicate Flow or Production?
Yes
SIU sends POTW a monthly sheet
40.
During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
Yes
41.
a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations
b. Did Industry Resample Within 30 Days?
N/A
N/A
42.
Was the SIU Promptly Notified of any Violations (Per ERP)?
N/A
43.
During the Most Recent Semi -Annual Period, Was the SIU in SNC?
No
44.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
N/A
45.
Does the File Contain Penalty Assessment Notices?
N/A

46.
Does the File Contain Proof of Penalty Collection?
N/A
47.
a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
N/A
N/A
48.
Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information for You?
No
FILE REVIEW COM1VIENTS
PCI SUMMARY AND COMMENTS
PCI Comments:
1. Intek closed at approximately the end of March 2004; it contributed approximately 5% of the flow to the POTW.
The Drop Approval letter was dated 06/28/04 from the Pretreatment Unit.
2. Gulistan Carpet Corp. Textile are on a local permit.
3. Ingersoll-Rand is on a local permit.
4. In the future, if Thermal Metals would discharge to the POTW, they will probably be treated as a CIU (since they
perform a phosphoric acid dip in their process).
5. Kainos is on a local permit, they have not started business yet. Their products are silver glass fiber, silver 200,
and glass spheres.
6. The POTW sends all of its outside testing to Meritech.
Requirements:
Recommendations:
1. Recommend that the Slug Control Plan be reviewed and updated. The date on the Slug Control Plan was 11/10/98,
and Richard Macary (the plant manager) is no longer there.
2. Please refer to the IUP and to the NC Comprehensive Guidance for the possibility that a TTO certification letter wou
be sufficient, instead of sampling. The certification letter would state that there were no organic solvents discharged
from the SIU to the POTW during the required time period.
NOD:
NOV:
QNCR:
NO
NO
liVO
POTW Rating:
Satisfactory ✓ Marginal Unsattory
PCI COMPLETED BY: Dale Lopez, Environmental Specialist
Name and Signature of Reviewer Agency/Office/Telephone
t
/21/04
Date
NCDENR/Fayetteville/[phone] 10/21/04

INDUSTRY INSPECTION. CODING:
No Industrial Inspection was conducted during the PCI Inspection
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
JN( 1 NI CI0 10 1 1 1 1
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4.Industry Contact: Title:
Phone:
/-/- 111 1S1 LJ
(DTIA) (TYPI) (1NSP) (FACC)
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
f /�. 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 II.JI 2 U 3 I NC0037508 111 121 04/09/08 117
Type Inspector Fac Type
18 [21.1 19 U 20 U
Remarks
2111111111111111111111111I11I1111111111111.111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
67 I 169 70 U 71 u 72 U 731 1 174 751 I I I I III 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 Add.oi Rd
Aberdeen NC 28315
Entry Time/Date
10:00 AM 04/09/08
Permit Effective Date
00/06/01
Exit Time/Date
02:00 PM 04/09/05
Permit Expiration Date
04/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Jeffery W Corder/ORC/910-281-3146/
/1/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Gary A Frick,PO Box 813 Pinebluff NC 28373//910-281-3146/ No
Section C: Areas Evaluated During Inspection (Check only those
areas evaluated)
Pretreatment ® Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax
Dale Lopezt at. � 0 FRC AQ//910-486-1.5e1/ 910-48E-0707
Numbers Date
f / � y;
Signature of Mansngement i er Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES
NC0037508.
11 121
yr/mo/day
04/09/08
Inspection Type
117 18 I n I
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional_ sheets of narrative and checklists as necessary) .
Satisfactory PCI. PCI Comments: 1) Intek closed on approximately the end of March 2004; it contributed
aproximateiy 5 of the flow to the POTW. The Drop Approval letter was dated 05/28/04 for the Pretreatment
Unit. 2) Gulistan Carpet Corporation:Textile is on a local permit. 3) Ingersoll-Rand is on a local permit.
4) In the future, if Thermal Metals would discharge to the POTW, they will probably be treated as a CIU
(since they perform a phosphoric acid dip.in their process)-. 5) Kainow is.on a local permit,' they have not
started business yet. Their,products are silver glass fiber, silver 200, and glass spheres. 6) The POTW sends
all of its' outside testin to Meritech. Recommendations: 1)" We recommend that the Slug Control Plan be
reviewed and updated.' The date on the Slug Control Plan was 11/10/98, and Richard Macary , the plant manager,
is no longer working there. 2)'Please refer to the 1UP and to the NC Comprehensive Guidance for the
possibility that a certification letter would be sufficient, instead of sampling for TTO. The certification
letter would state that there were.no organic solvents discharged from the SIU to the POTW during the
required time.period. •

Department of Public Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
aunty a/ aaxe
November 3, 2004
Mr. Dale Lopez
N.C. Division of Water Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301-5043
Mr. Lopez,
fidt59.
740'
)
910 Telephone: 281'-3146
P (
Facsimile: [phone]
DENR-- R
NOV 8 - 2004
\,,t
0
I received a copy of the Pretreatment Compliance Inspection Report for the inspection
conducted on September 8, 2004 on October 27. A response was not requested but I felt
it appropriate to respond to your recommendations.
The first recommendation was that the Slug Control Plan be reviewed and updated for
ERICO Industries. Please find attached a letter that was sent to Jarvis McDaniel, Plant
Manager, requesting this update:
The second recommendation was to refer to ERICO's IUP and to the NC Comprehensive
Guidance for the possibility that a TTO certification letter would be sufficient instead of
sampling. I have discussed this matter with Jon Risgaard, DWQ-PERCS Unit. The TTO
minimum requirement is annual sampling unless they wish to use a Certification
statement. I am looking into this issue to see if it is a requirement in Moore County's
SUO. I will make a determination on this issue after I have looked through the SUO and
Pretreatment Standards.
If you have any questions or concerns please contact me at 910-281-3146.
Sincerely,
054.haold cortA
Stephanie A. Brixey
Chemist/IPP Coordinator
Cc: Mr. Phillip Boles, Moore County Public Works Director
Mr. James Frye, Moore County WWTP Superintendent

Stephanie A. Brixey
Chemist/IPP Coordinator
Department of Public Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
Wounty 7 tcLa-xe
October 21, 2004
Mr. Jarvis Daniel, Plant Manager
ERICO, Incorporated
188 Carolina Road
Aberdeen, NC 28315
Mr. Daniel,
Telephone: [phone]
Facsimile: [phone]
....4.--.:,,t . -.,-,1) -ve• ••••
0
Permit # A005
From my understanding there has been a change at ERICO in personnel. Due to this the
Emergency Contact information on the Sludge Management Plan and Slug/Spill Control
Plan will need to be revised. I am requesting the new revisions of these two plans.
Recently in a Pretreatment Inspection conducted by DENR at the Moore County Water
Pollution Control Plant a few questions were asked concerning the sampler and flow
meter at ERICO. Please find the questions of interest attached. Joe Holt may be the one
who needs to answer these. If so, please ask him to send me the answers as soon as
possible.
If you have questions or concerns please feel free to contact me.
Sincerely,
0

Department of Public Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315
�p 0€1M't a/ C�(0axe
Telephone: [phone]
Facsimile: [phone]
Questions of interest:
I. When sampling, how much and how often does the composite sampler pick
up?
2. Who calibrates your flow meter?
3. How is your flow meter calibrated?
4. Why does all of the flow numbers end with---000?
5. How do you determine the flow numbers? (Is it from potable water, etc.?)