NC0037508_Pretreatment Audit_20040414

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
April 14, 2004 Coleen H. Sullins, Deputy. Director
Division of Water Quality
Phillip Boles
Moore County Public Works Director
P.O. Box 756
Carthage, NC 28327
SUBJECT: Pretreatment Audit Report
Moore County Water Pollution Control Plant
NPDES Permit No. NC0037508
Moore County
Dear Mr. Boles:
This Pretreatment Audit Report relates the pretreatment audit that was held at the Moore
County Water Pollution Control Plant on April 6, 2004. Jon Risgaard of the DWQ Pretreatment
Unit and Dale Lopez of the DWQ Fayetteville Regional Office met with Jeff Corder (Pretreatment
Coordinator) to review the POTW's Pretreatment Program records. A file review was performed
on the records of Erico and Intek. An Industrial Inspection was conducted at Erico. The Audit
indicates that the City is properly implementing its Division approved Pretreatment Program. The
details of the Audit are provided in the attached Audit form. Please review it carefully as it
contains various requirements, especially in the AUDIT SUMMARY AND COMMENTS section
on page 6. Where recommendations and requirements are cited, we ask that you provide a written
description of how each has or will be addressed. We ask that your response be forwarded to the
Fayetteville Regional Office by May 10, 2004, unless specified differently in the Audit Form.
We appreciate your cooperation. You are commended for your continued success in
maintaining your Pretreatment Program. If you have any questions, please do not hesitate to
contact Jon Risgaard at [phone] ext. 580 or Dale Lopez at [phone] ext. 712.
. Dale Lopez
Environmental Specialist
JR/DL: DL/dl
Enclosure: Pretreatment Audit Report
Verification of Applicable Standards and Reporting Requirements for Electroplaters and Metal Finishers
cc: Jon Risgaard, DWQ Pretreatment Unit
Jeff Corder, Pretreatment Coordinator One
NorthCarolma
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043 �atur►a////
Phone: [phone] FAX:. [phone] Internet: www.enr.state.nc.us/ENR/
An Equal Opportunity! Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper

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
2. Control Authority Representative(s): Jeff Corder [e-mail]
3. Title(s): _Lead Operator
4. Address of POTW:
Mailing: 1094 Addor Rd
City Aberdeen
Phone Number 910 281-3146
5. Audit Date 04 / 06 / 2004
6. Last Inspection Date: _10 /_24 / 2002 Inspection Type (Circle One):
Zip Code: 28315
Fax Number 910 281-2047
PCI
Audit
7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? o
If No, Explain.
Recommendations only: Improve computer data tracking — Asked to contact Lumberton or Fayetteville about PreWin data
tracking program.
Remove TTO from Intek IUP - Done
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems. �� o
If Yes, Explain.
There were some monitoring violations. Jeff was unaware of these, but thought they were due to changes in personnel.
9. Is POTW under an Order That Includes Pretreatment Conditions? Ye 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
I N I LN_LC_Lo_La_L3-L7_L5_I_o_�_8_� 04/_06 /2004 1 G 1 I Ll J
(DTIA) (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users (SIUS)? 2 SIUS
11. Current Number of Categorical Industrial Users (CIUS)? 1 CIUS
12. Number of SIUs Not Inspected by POTW in the Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in the Last Calendar Year?
14. Enter the Higher Number of 12 or 13
15. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of S1Us in SNC)
16. Number of SIUs with No IUP, or with an Expired IUP
0
0
0
0
0
NOIN
PSNC
17. Number of SIUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods
18. Number of SIUs in SNC for Limits Violations During Either of the Last 2 Semi -Annual Periods
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods
0
0
0
MSNC
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
0
SNIN

PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headworks Analysis (HWA)
10/6/03
4/1/08
Industrial Waste Survey (IWS)
3/16/04
9/1/08
Sewer Use Ordinance (SUO)
10/7/97
Enforcement Response Plan (ERP)
4/27/98
Long Term Monitoring Plan (LTMP)
9/2/98
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
If yes, Please list.these towns and/or areas. Camp MacKall Army base
22. If yes to #21, do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Unknown
The County must verify if one exists and a copy, if not already submitted, should be sent to Division.
23. If yes to #21, have you had any trouble working with these towns or districts? Yes No
If yes, explain.
24. Date of Last SUO Adoption by Local Council _7 /_21_/ 03
25. Have you had any problems interpreting or enforcing any part of the SUO? Yes
If yes, explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? Unknown
County will verify and send current copy within 30 days if industries do not have a -copy.
27. e you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudications, improper enforcement, etc.)? Yes
/ No If yes, Explain.
Has yet to use the ERP, but seems clear to County on how to use.
28. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
29. Please Rate the Following:
=Satisfactory M=Marginal
U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
S
WWTF is understaffed leading to greater demand to perform other
duties. Stephanie Brixey (Chemist) performs pretreatment duties as
well. There is some confusion on who is responsible for what.
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
S
2 vehicles on site, usually I available
Access to Operable Sampling
Equipment
S
Multiple samplers on site
Availabity of Funds if Needed for
Additional Sampling and/or Analysis
S
Reference Materials
S
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S
Would like to attend permit writing workshop.
Computer Equipment (Hardware and
Software)
S

30. Does the POTW have an adequate data management system to run the pretreatment program?
No Explain Yes or No: Use Excel Spreadsheet to track data. Input data irregularly. It is recommended that the County
enter in monitoring data as soon as it is made available, or at least once per month, in order to judge compliance in a timely
manner.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Cost recovered through sampling charges. Considering surcharge in the future.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
No If yes, Explain. Intek will close. Possibly 3 new industries
33. Has any one from the public ever requested to review pretreatment program files? Ye / No
If yes, explain procedure. If no, how would the request be addressed? It was not known dart official procedure for viewing of files
has been established. It is recommended that the County develop a procedure that requires the public to make a request via
appropriate County officials (county supervisor, WWTF superintendent, or other) before they are granted permission.
34. Does the POTW have a procedure in place that addresses requests by an industry for certain information to remain confidential?
Unknown If yes, Explain. The County should establish a procedure for maintaining confidential files in a separate file
clearly marked "confidential". This information should be verified by the industry and should not include characteristics of
effluent wastewater.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment
Minimum of monthly contact with all SIUs. Good relationship wit l rico.
36. Is the public notified about changes in the SUO or Local LimitsNo
37. Were all industries in SNC published in the last notice
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and
therefore require a permit? (Who is an SIU?) >25,000 gpd, short form, categorical classification, long form (if needed)
39. Does the POTW receive waste from any groundwater remediation (petroleum, CERCLA) or landfill leachate?
If Yes, How many are there? 1 Landfill transfer station
Please list each site and how it is permitted, if applicable.
No current permit. The County is required to include the transfer station in any upcoming IWSs. It is recommended
that that County sample the effluent periodically to determine if a threat to the WWTF exists.
40. Does the POTW accept waste by (circle if applicable)
Dedicated Pipe — Septic Haulers
41. If the POTW accepts trucked waste, what controls are placed on this waste? (Example. designated point, samples drawn,
manifests required) Septic haulers are permitted. Manifest is required, sample pH, and visually expect each load.
42. How does the POTW allocate its loadings to industries? Circle One
1.) Uniform Limits 2.) Historical Industry Need ; .) By Surcharge
Explain Other: -
43. Review copies of culTent allocation tables for each WWTP. Are there any over allocations? Yes
If yes, what parameters are over allocated?
.) Other
44. If yes to #43, what is being done to address the over allocations? (Short term IUPs, HWA to be revised, pollutant study, etc.)
45. Does the POTW keep pollutant loading in reserve for future growth / safety? o
If yes, what percentage of each parameter % - As much as possible, not set rules or percentage
46. Has the POTW experienced any difficulty in allocation? (For example: adjudication by an industry ? o
If yes, explain.
> 85% of capacity for Flow for some time. Loss of industry flow has resolved this issue.

47. 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)
Based on WWTF influent compared to industry data, Categorical Standards, State Pretreatment Unit requirements.
48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
A minimum of monthly sampling for all parameters is required
Permit Compliance
49. Does the POTW currently have or during the past year had any permits under adjudication? Ye• No
If yes, Which Industries, and what was (will be) the outcome of the adjudication?
50. 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. For all violations the S1U is contacted by phone and by letter. Re -
sampling is required within a few weeks; a written response is due in a few weeks as well.
51. Does the POTW use the Division's model inspection form or equivalent No
If no, does the POTW form include all DWQ data? Yes / No
52. Were all SIUs evaluated for the need of a slug and spill control plan during their most recent inspections?
If no, Explain.
53. What criteria are used to determine if a slug control plan is needed? All S1Us are required to have one.
54. What criteria does the POTW use to review a submitted slug control plan? Are contaminants containable? Is the Control Authority
called and when.
55. How does the POTW decide.where the sample point for an SIU should be located? Last point of discharge.
56. Has the POTW established a procedure to ensure that re•resentative samples will be taken by the POTW or SIU each time?
(Example: swirling the sample bucket uniformly) Ye. / No
If yes, explain. It is required that the County inspects the SIU's sampling technique to ensure that the sampling procedure is
adequate. It is recommended that the County develop a sampling SOP to ensure that the different staff that collects samples
are doing so consistently.
57. Who performs sample analysis for the POTW for
Metals TBL
Conventional Parameters _County Lab (TSS, BOD, pH)
Organics TBL
58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Both procedures are adequate. It is recommended that the signature line for the industry on the County's chain of custody
form used for SIU sampling be removed, or be labeled as optional, to avoid confusion on the viability of a sample taken by the
County without notifying the SIU or obtaining their signature. It is not required for the industry sign -off on the chain of custody
form, unless a'SIU representative physically handles the sample during the sampling event,
Long Term Monitoring Plan (LTMP) and Headworks Analysis (HWA)
59. Is LTMP maintained in a table? o
Review Data and Explain. The LTMP update is required to modify the mercury sampling requirements to reflect the requirements
associated with method 1631 for low-level detection of the effluent. The Sampling locations also need to be reviewed. The
County is required to submit an updated LTNIP by June 25, 2004. Please contact the Pretreatment Unit with any questions or
for clarifications of requirements.
60. Do you complete your own headworks analysis (HWA
If no, who completes your HWA? Phone ( )
61. Do you have plans to revise your headworks in the near future? Ye
If yes, what is the reason for the revision? (Circle one)
1.) Increased average flow
4.) More LTMP data available
Explain.
2.) NPDES limits change 3.) Other
5.) Resolve over allocation 6.) 5 year expiration

_ 62. In general, what is the most limiting criteria of your HWA?
1.) Pas
Inhibitions 2.) s Through 3.) Sludge Quality
63. Do you see any way to increase your loadings in the future (Example: obtaining more land for sludge disposal)? Yes
Explain.
Summary
64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Loss of Intek, Possible addition of three new SIUs (Seaboard, Kainos, Thermal Metal)
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS)
65. User Name
1. Erico
2. Intek
3.
66. IUP Number
A005
A004
67. Does File Contain Current Permit?
Yes
/ No
See Note #2
Yes
/ No
Yes / No
68. Permit Expiration Date
06 /30 /04'
06 /30 /04
69. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
70. Does File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
71. Does File Contain an Inspection Completed Within Last Calendar
Year?
433 or 413
N/A
Yes
/ No
12/30/02
Yes
/ No
Yes / No
Yes
/ No
10/14/03
Yes
/ No
10/16/03
Yes / No
72. a. Does the File Contain a Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
73. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
Organic Management Plan (TOMP)?
74. a. Does File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
a. Yes / No
b.Yes/No
/No/N/A
Yes
a. Yes / No
b. Yes /No
a. Yes /No
b. Yes /No
Yes / No /
N/A
Yes/No/
N/A
a.
b.
Yes' / No
Yes' / No / N/A
a. 'Yes / No
b. Ycs / No /
N/A
a. Yes/No
b. Yes / No /
N/A
75. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by IUP?
Yes / No1
See Note #1
Yes
/ No
Yes / No
.76. Does File Contain POTW Sampling Chain -Of -Custodies?
Yes
/ No
Yes
/ No
Yes / No
77. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required by IUP?
78. Does Sampling Indicate Flow or Production?
79. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
80. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self -
Monitoring Violations?
b. Did Industry Resample Within 30 Days?
Yes
/ No / N/A
Yes
/No/N/A
Yes / No /
N/A
Yes
/ No / N/A
Yes
/ No / N/A
Yes / No /
N/A
Yes
/ No
Yes/No
Yes / No
a. Yes/ No /
b. Yes / No
N/A
a. Yes / No/
b. Yes / No
N/A
a. Yes / No /
N/A
b. Yes / No
81. Was the SIU Promptly Notified of Any Violations (Per ERP)?
Yes / No / N/A
Yes / No / N/A
Yes/No/
N/A
82. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
83. During the Most Recent Semi -Annual Period, Was Enforcement
Taken as Specified in the POTWs ERP?
84. Does the File Contain Penalty Assessment Notices?
Yes /
No
Yes /
No
Yes / No
Yes / No /
Yes / No /
N/A
N/A
Yes/No/
N/A
Yes / No /'N/AI
Yes / No /
N/A
Yes / No /
N/A
85. Does The File Contain Proof Of Penalty Collection?
Yes / No /
N/A
Yes / No / N/A
Yes/No/
N/A
86. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
N/A
a. Yes / No /
b. Yes / No / N/A
N/A
a. Yes/No/
N/A b. Yes /
No / N/A
87. Did the POTW Representative Have Difficulty in Obtaining Any of
This Requested Information For You?
Yes /
No
Yes / No
Yes / No
a. Yes/No/
b. Yes / No / N/A

FILE REVIEW COMMENTS:
Note #1 See the 2003 PAR, the Silver that was missed should be added to the list of semi-annual sampling that was noted in
the PAR as being inadvertently missed (along with TSS, Chromium, Lead, Zinc, and Aluminum). Usually a missed
POTW sample -monitoring event warrants an NOV to the pennittee from DWQ, with make-up samples for those that
were missed. However, the extenuating circumstances surrounding the POTW's November 2003 missed sampling
oversight will only be documented.
Note #2 The APAM requirement on the IUP limits page indicates with " *** " to review Form A for instructions. However,
Form A was not attached to the IUP. Please correct.
Erico Limits The Erico IUP includes monitoring only of a ntunber of POCs that are not required to be included in the IUP. These
POC include APAM, aluminum, molybdenum, TKN, ammonia nitrogen, total nitrogen, total phosphorus, chlorides
and iron. All of these POC except APAM are included in the county's LTMP, and while it is recommended that the
County sample these parameters at least once for each HWA, it is not required that the County include the parameters
in the IUP. APAM is not in the Current LTMP, nor is it a parameter in the County's current NPDES permit.
Removing APAM from the IUP may provide some cost savings to the SIU. Similar IUP modifications can also be
made to the Intek permit prior to plant closing if the County chooses.
Audit SUMMARY AND COMMENTS:
Audit Comments: It was noted that the POTW's influent wastewater is now being sampled (as of April 4, 2004) at a point that is located
before any in -plant recycle flow. The POTW is commended for the influent sampling site and its recent modifications.
Requirements: questions #22, 26, 39, 56, 59
Recommendations: questions #30, 33, 34, 39, 56, 58,_Erico Limits (see above)
NOD: YES
NOV: YES
QNCR: YES
POTW Rating:
NO
NO
NO
Satisfactory "J Marginal UnSatisfactory
Audit COMPLETED BY: Jon Risgaard (Central Office) &Dale Lopez (FRO) DATE: 04/014/04

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
NI I N I C I 0 I 0 I 3. 1 7 1 5 1 0 1 8 1 1 041061 041 11 I 1 S I 1 2 l •
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
Erico, Inc
188 Carolina Road, Aberdeen, NC 28315
Electroplating ground rod manufacturing with nickel, zinc, and copper.
4. Industry Contact:Richard M. Macary Title: Ground Rod Manufacturing Manager
FAX [phone]
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 Yes
B. Plant Tour Yes
C. Pretreatment Tour Yes
D. Sampling Review No
E. Exit Interview Yes
Industrial Inspection Comments:
Effluent flow proportional sampling at a frequency of 250 mL/500 gallons of effluent flow. Therefore, a 24-
phone[phone]
hour sampling period that had 16,500 gallons of flow should have 8,250 mL in the composite container at the
end of the 24-hour period.
There was a question concerning whether Erico should beconsidered a 433 or a 413 categorical user. They
have always been categorized as a 433 industry. However, the industry indicated that they were a 413
discharger in the last permit application, I have attached a guidance document that is helpful in determining if
an industry should be categorized as either 413 or 433. From the information I have, itappears that Erico has
been correctly categorized as a 433-type discharger.
North Carolina Pretreatment Audit Form
Page 7