NC0020427_Pretreatment Inspection_20050803

Michael F. Easley, Governor
ATA
NCDENR
North Carolina Department of Environment and Natural Resources
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
August 3, 2005
CERTIFIED. MAIL
RETURN RECEIPT REQUESTED
Mr. Larry Cobbler, Director of Plant Operations
City of Rockingham
514 Rockingham Road
Rockingham, NC 28379
SUBJECT: Failure to Enforce with Notices of Violations
Pretreatment Compliance Inspection (PCI)
City of Rockingham Wastewater Treatment Plant, NPDES Permit NC0020427
Richmond County
Dear Mr. Cobbler:
Enclosed you will find a copy of the Pretreatment Compliance Inspection Repoli for the inspection
conducted on July 28, 2005 at the City of Rockingham Wastewater Treatment Plant. The report indicates
that the Rockingham WWTP does not meet the pretreatment requirements as outlined in 15A NCAC 2H
.0900 for Local Pretreatment Programs for failure to follow the City of Rockingham's Enforcement
Response Plan (ERP), that is to say that the POTW did not send Notices of Violations to UCO Fabrics, Inc.
(IUP# 0008) for nine Total Suspended Solids (TSS) limits violations during the first half of 2004 and to
Cascade Tissue Group (IUP#004) for ten Biochemical Oxygen Demand (BOD) limits violations during the
second half of 2004. The report is self-explanatory and contains observations, recommendations, and
requirements, Please send DWQ-Fayetteville Regional Office a written reply to the recommendations and
requirements.
712.
If you any questions, please do not hesitate to contact Dale Lopez at [phone] extension
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
Enclosure: Pretreatment Compliance Inspection (PCI) Report
cc: Deborah Gore, DWQ Pretreatment Unit One
NorthCarolina
225 Green Street - Suite 714, Fayetteville, North Carolina 28301-5043 NatgrallifPhone: 910-486-15411 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 COMPLIANCE INSPECTION (PCI) REPORT
FAYETTEVILLE REGIONAL OFFICE
1. Control Authority (POTW) Name: City of Rockingham WWTP
2. Control Authority Representative: Larry Cobler
3. Title(s): Pretreatment Coordinator/ ORC/Plant Operations Director
4. Last Inspection Date: 10/12/04 Inspection Type (Circle One): P�I 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
Yes
/No
Yes /
No
PCS CODING
Trans.Code Program NPDES Number MM/DD/YY Inspec.Type Inspector Fac.Type
J N J J NI CIO 1_0 12 10 14 12 17 f 07 / 28 /05 LJ LJ 1 1 1
(DTIA) (TYPI) (INSP) (FACC
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?
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?
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?
8
1
0
0
0
0
0
0
0
SIUS
CIUS
NOIN
NOCM
PSNC
MSNC
SNPS
YES
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)
SNC for 'Limits: 0
SNC for Reporting: 0
Not Published: C
20. a. Which Industries are on Compliance Schedules or Orders? b. For all SIUs on an Order,
Has a Signed copy of the Order been sent to the Division?
Compliance Schedule effective
May 18, 2005, and expires September 1, 2005. UCO has already achieved'compliance.
Corrective actions for excessive amount of blue lent: 1) cleaned out the dye pit, 2) installed -a
screen to prevent lent from going into the pit, 3) discovered that it is related to the use of
Color #24.l
21. Are any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which Ones?
a. UCO
b. Yes
YES.
INO
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)
02/28/2002
04/01/06
Industrial Waste Survey (IWS)
06/21/04
04/05/2009
Sewer Use Ordinance (SUO)
11/13/94
Enforcement Response Plan (ERP)
1 1 / 19/04
Long Term Monitoring Plan (LTMP
09/11/00
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?
If Yes, which ones? Eliminated: Added:
24. Are Correct Detection Levels being used for. all LTMP Monitoring?
25. Is the LTMP Data Maintained in a Table or Equivalent?
Yes
/ No Is the Table Adequate?
Hayes, Seay, Mattern, and Mattern Engineering (Florence, SC), PT engineers compile the data
IYes
INo
Yes
N/E

INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26. User Name
Laurel Hill Paper
Cascade Tissue Group, formerly
Perkins. Paper
27. IUP Number
0010
0004
28. Does File Contain Current Permit?
Yes, effective
04/01/05
Yes, 07/01/01
29. Permit Expiration Date?
06/30/05
06/30/06
30. Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
N/A
N/A
31. Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
Yes,
12/.18/00
Yes,
11/30/00
32. Does the File Contain an Inspection Completed Within Last Calendar
Year?
Yes, 12/01/04
Yes, '
12/02/04
33. a. Does File Contain A Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes, Reviewed
04/15/02
a. Yes, will have
an updated
version in
Aug/Sept 2005
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain A
Toxic Organic Management Plan (TOMP)?
N/A
N/A
35. a. Does the File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved?
a. Yes,
07/20/04
b. Yes
Yes,
07/20/04
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
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?
a. N/A
b. N/A
a. N/A
b. N/A
42. Was the SIU Promptly Notified of any Violations (Per ERP)?
N/A
N/A
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
N/A
45. Does the File Contain Penalty Assessment Notices?
N/A
N/A
46. Does the File Contain Proof of Penalty Collection?
N/A
N/A
47. a. Does the File Contain any Current Enforcement orders?
b. Is SIU in Compliance with Order?
a. N/A
b. N/A
N/A
48. Did the POTW Representative Have Difficulty in Obtaining any of this
Requested Information. for You?
No
No

PCI SUMMARY AND COMMENTS
PCI Comments:
1. Recently a $1,500,000 grant has been approved. On 08/16/05, bids will be placed for two new aerobic
digesters, replacement of the bar screen, all handrails, and replacement of the trickling filter distributor arm.
2. IUPs will expire 06/30/06. Two weeks ago, applications were sent to the SIUs.
3. During March 2005, blue lint appeared at the bar screen. It was traced back to UCO. A Compliance
Schedule to correct the lint problem became effective on May 18, 2005, and it expires on September 1,
2005; UCO has already achieved compliance. The following are the corrective actions for reducing the
excessive amount of blue lint: 1) cleaned out the dye pit, 2) installed a screen to prevent lintfrom going into
the pit, 3) discovered that the lint problem was related to the use of Color #24.
4. Notices of Violations were not sent to UCO Fabrics, Inc. (IUP# 0008) for nine Total Suspended Solids
(TSS) limits violations during the first half of 2004, nor were they sent to Cascade Tissue Group (IUP#004)
for ten Biochemical Oxygen Demand (BOD) limits violations during the second half of 2004.
5. On April 1, 2005, Trinity Manufacturing was sent an NOV for a BOD limit violation. The NOV letter
required that Trinity Manufacturing should respond back to the POTW within 30 days of receiving the
NOV as to the cause of the BOD violation. This response as not found in the PT files.
6. On February 21, 2005, Cascade Moulded Pulp was sent an NOV, for a January 4, 2005 BOD limit violation.
The NOV letter required that Cascade Moulded Pulp should respond back to the POTW within 30 days of
receiving the NOV as to the cause of the BOD violation. This response as not found in the PT files.
7. During the July 1, 2004 to June 31, 2005 fiscal year time period, there was slightly greater than $750,000 of
surcharges issued to the SIUs. Cascade Tissue Group paid the majority (approximately $500.000) and the
other seven SIUs paid the rest of the amount.
Recommendations: .
1. Recommend that the POTW use a form to keep track of the due dates. The following columns are
suggested items: Due Date, SIU Name, Materials Requested, Type of POTW Letter sent, Adequate/Not
Adequate/More Information Needed.
2. Recommend that the POTW write or stamp the date that each commercial laboratory report sheet is
received, SIU correspondence that is received by the POTW. DWQ-FRO also recommends that the same
be requested of each SIU so as to keep a record of when an report/correspondence letter is received by the
SIU.
Requirements: Please send the following items to the SIUs.
1. Notice of Violation to UCO Fabrics, Inc. (IUP# 0008) for the nine Total Suspended Solids (TSS) limits
violations during the first half of 2004.
2. Notice of Violation to Cascade Tissue Group (IUP#004) for the ten Biochemical Oxygen Demand (BOD)
limits violations during the second half of 2004.
3. Notice of Violation: to Trinity Manufacturing for "not reporting" to the POTW as to the cause of the BOD
limit violation (as according to the April 1, 2005 NOV letter).
4. Notice of Violation to Cascade Moulded Pulp for "not reporting" to the POTW as to the cause of the
January 4, 2005 BOD limit violation (as according to the February 21, 2005 NOV letter).

NOD: YES.
NOV:
YES
QNCR: YES
NO
NO
POTW Rating:
Satisfactory Marginal - Unsatisfactory X
PCI COMPLETED BY: Dale Lopez, Environmental Specialist . Date: 08/02/05
REVIEWED BY: Belinda S. Henson, Regional Supervisor, Surface Water Protection Section
INDUSTRY INSPECTION CODING:
No industrial site inspection was performed during this PCI
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
jJ IN IC10101 1 1 I I I / / J I 1 '!Sl J 2 1 .
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
5. Phone: Fax:
6. Does the POTW use The Division Model Inspection Form or Equivalent? Yes / No
7. 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:

Larry Cobler
Wastewater Plant Operations Director
ROCKINGHAM
A CITY' LOOKING FORWARD
August 10, 2005
N.C. DEPARTMENT OF ENR
SURFACE WATER PROTECTION SECTION
ATTN: BELINDA S. HENSON, REGIONAL SUPERVISOR
225 GREEN STREET -SUITE 714
FAYETTEVILLE, N.C. 28301-5043
„a/A:141,2-c
0-1
RECEIVED.
AUG 11 2005
1 DENR - FAYETTEVILLE REGIONAL OFFICE
Dear Belinda,
Let me start by assuring youthat it is not the City of Rockingham's policy
not to implement its ERP. As you know from past experiences the City has
always been a strict enforcer of the pretreatment program to insure protection of
the POTW and receiving stream. Although the violations that occurred at the
industries in no way jeopardized the quality of our effluent or the operation of
the POTW, it is still our responsibility to monitor and serve notice to any
industrial user that violates their limits and the limits set forth in the Sewer Use
Ordinance. The City regrets that these NOV's were not issued and assures you
that this will not happen again in the future.
Certain steps have been taken to correct this problem as required by your
August 3, 2005 letter to the City. Listed below are the actions that have been
taken thus far:
A form to track NOV's and response time has been created and a copy is
enclosed with this information.
A stamp was purchased to document when lab data is received from our
commercial lab. A sample stamp is enclosed.
All NOV's that should have been, and the ones that were issued in 2004 were
resubmitted to all industrial users for there files including UCO and Cascades
Tissue Group with copies placed in City files also.
The NOV that was issued to Trinity in April 2005 was sent in error. When their
data and the City's data was averaged, they were within their permit limits. They
have been notified of this error and the City requires no response.
200 Byrd Drive, Rockingham, NC 28379 • Phone [phone] • Fax [phone] • [e-mail]

Larry Cobler
Wastewater Plant Operations Director
ROCKINGHAM
A CITY' LOOKING FORWARD
Cascades Molded Pulp has been issued a NOV for not responding to the February
21, 2005 NOV.
I apologize for any inconvenience that this has caused and again assure
you that this is not the way the City of Rockingham runs it's pretreatment
program and this will not happen again in the future.
Sincerely,
rry D. Co Ier
Plant pe ions Director
City of Rockingham, WWTP
200 Byrd Drive, Rockingham, NC28379 - Phone [phone] - Fax [phone] • [e-mail]

NOV TRACKING FORM
I.U. NAME
ACTION
TAKEN
DATE MAILED
TO I.U.
DATE.
RESPONSE
REQUIRED BY
I.U.
DATE
RECEIVED BY
POTW
RESPONSE
ADEQUATE
(Y or N)

Cobler W?""\'‘
RoCKINGHAM
Wastewater Plant Operations Director
A CITY LOOKING FORWARD
Af!
200 Byrd Drive, Rockingham, NC 28379 • Phone [phone] • Fax [phone] • [e-mail]