NC0020427_Pretreatment Inspection_20000128

,„.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
,January 28, 2000
• Mr. Larry Cobler
Director of Plant Operations
City of Rockingham
PO Box 250
Rockingham, NC 28379
• DIVISION OF WATER QUALITY
FAYETTEVILLE REGIONAL, OFFICE
SUBJECT: Pretreatment Compliance Inspection
City of Rockingham
NPDES Permit No. NC0020427
Richmond County
Dear Mr. Cobler:
Enclosed please find a copy of the Pretreatment Compliance Inspection
Report for the inspection conducted on Janua,ry 20, 2000. During the inspection,
an SIU (Trinity Manufacturing, Incorporated) was inspected and records were
reviewed for this facility. The report reveals a summary and observations of the
City's prCtreatment program. •
The conclusion ofthe inspection was that the City administers a program
that monitors SIUs and enforces rules and regulations as deemed necessary for the
proper administering of the pretreatment program. You are commended for your
continued success in maintaining your program in'such a manner that has ensured
the best water quality to the stream as well as maintaining the NPDES permit
limits. •
Please review the attached report. If you or your staff have any questions,
do not hesitate to call me at [phone] ext. 340.
Sincerely,
DL/bs
Enclosures
cc: • DWQ Pretreatment Unit
Dale Lopez
Environmental Specialist II
SCI;.01.1
Egr
EMEMIMMI
225 GREEN STREET, SUITE.714 / SYSTEL BLD. FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1O% POST -CONSUMER PAPER
• •
1.. ..,..
• c4

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION REPORT
FAYETTEVILLE REGIONAL OFFICE
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: City of Rockingham WWTP
2. Control Authority Representative: Larry Cobler
3. Title: Plant Operations Director
4. Last Meeting: June 16, 1999 Inspection Type (Circle One): I Audit
5. Has Program Completed All Requirements From The Previous Inspection or Program Info Sheet(s)? / No
6. Is POTW Under An Order That Includes Pretreatment Conditions? Yes /©o
Order Type And Number: N/A Are Milestone Dates Being Met? Yes / No
PCS CODING 1
Trans.Code Program NPDES Number MM/DD/YY Inspec.Type Inspector
INI f NI Cf 0 f 0 f2 10 f4 f2 17 f 01/20/00 I P _ S_
(DTIA) (TYPI) (INSP) .
7. Current Number Of Significant Industrial Users (SIUS)?
8. Current Number Of Categorical Industrial Users (CIUS)? Trinity Manufacturing , Inc.
Fac.Type
111
(FACC)
SIUS
10
1
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
12. Number Of SIUS With No IUP, or With An Expired IUP?
0
CIUS
NOIN
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)?
14. * Number Of SIUS In SNC For Reporting (Owens and Wundies) 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?
2
2
0
0
PSNC
MSNC
SNPS
* Owens failed to do their third quarter monitoring.
Wundies failed to complete their first and second quarter analysis for total suspended solids, biochemical oxygen demand, and
their annual metal analysis
Filename: NCPCIWP
Page 1
Date: 1/28/2000

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?
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?
Yes /(E)
Yes / No
SNC for Limits: None
SNC for Reporting: Owens and Wundies
Not Published:
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?
PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files and complete the following:
Trinity Manufacturing
Company
Yes
No
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headworks Analysis (HWA)
5/23/97
Industrial Waste Survey (IWS)
7/17/97
Sewer Use Ordinance (SUO)
10/13/94
Enforcement Response Plan (ERP)
8/31/94
Long Term Monitoring Plan (LTMP)
9/10/97
LTMP File Review:
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? / No
23. Should any Pollutants of Concern be Eliminated From or Added to the LTMP? Yes / No
If Yes, Which Ones? Eliminated: Added:
24. Are Correct Detection Levels Being Used for all LTMP Monitoring?
/ No (with Burlington Research)
25. Is the LTMP Data Maintained in a Table or Equivalent? Yes / No Is the Table Adequate I'ej/ No
Filename: NCPCIWP
Page 2
Date: 1/28/2000

INDUSTRIAL USER PERMIT (UP) FILE REVIEW
26. User Name
1.Trinity Manufacturing, Inc.
27. IUP Number
2.
28. Does the File Contain Current Permit
29. Permit Expiration Date?
30. Categorical Standard Applied (I.E. 40 CFR 413, Etc.) or N/A
The baseline monitoring report has been sent to Dana Folley.
31. Does the File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
32. Does the File Contain an Inspection Completed Within the Last
Calendar Year? 12/15/99
33. a. Does The File Contain a Slug Control Plan?
b. If No, Is One Needed? (See Inspection Form from POTW)
34. For 40 CFR 413 And 433 TTO Certifiers, Does The File Contain a
Toxic Organic Management Plan (TOMP)?
35. a. Does the File Contain Original Permit Review Letter from the
Division?
b. All Issues Resolved? 12/16/93
36. During the Most Recent Semi -Annual Period, Did the POTW
Complete its Sampling as Required by UP? The POTW did more than
required.
37. Does the File Contain POTW Sampling Chain -Of -Custody's?
Excellent form.
38. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required By IUP?
39. Does Sampling Indicate Flow or Production? On BOD sheet and
surcharge sheet.
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
41. a. Was the POTW Notified by SIU (Within 24 Hours) of all Self -
Monitoring Violations?
b. Did Industry Resample Within 30 Days?
Filename: NCPCIWP
Page 3
Date: 1/28/2000
3.
0009
a. es / No
a. Yes / No
a. Yes / No
6/30/01
Yes No
Yes / No
Yes / No
el No
t
Yes i- No
Yes / No
a.1 - / No
b. CD / No .
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
ED
Yes / No
N/A
Yes / No
N/A
a. 4a)/ No
b. le / No
a. Yes / No
b. Yes / No
a. Yes / No
b. Yes / No
•/ No
Yes / No
Yes / No
ea)/ No
Yes / No
Yes / No
0 / No
Yes / No
Yes / No
Yes / No
Fes / No
Yes / No
'es / No
N/A
Yes / No
Yes / No
a.Ye NoN/A
.110 NoN/A
a. Yes / No
b. Yes / No
a. Yes / No
b. Yes / No

42. Was the SIU Promptly Notified of any Violations (Per ERP)?
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
44. During the Most Recent Semi -Annual Period, Was Enforcement
Taken as Specified in the POTWs ERP?
45. Does the File Contain Penalty Assessment Notices? None Assessed
46. Does the File Contain Proof of Penalty Collection? None Collected
47. a. Does the File Contain any Current Enforcement Orders?
None under Orders
b. Is SIU in Compliance With Order?
48. Did the POTW Representative have Difficulty in Obtaining any of this
Requested Information for You?
Yes No N/A
Yes / No
Yes / No
CO/ No
Yes / No
Yes / No •
es / No N/A
Yes / No
Yes / No
Yes 0 N/A
Yes / No -
Yes / No
Yes /©o N/A
Yes / No
Yes / No N/A
a.Yes,1/A
a. Yes / No
b. Yes / No
a. Yes / No
b. Yes / No
b.Yes/Nt$
Yes No
Yes 1h No
Yes / No
PCI SUMMARY
PCI Comments:
The pretreatment program for this facility was well organized and all information was readily available. The facility had excellent
document forms for Chain -of -Custody and Notice of Violations.
Requirements:
Recommendations:
NOD: Yes / No
NOV: Yes / No
QNCR: Yes G
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Dale Lopez. Environmental Specialist II _ i
Filename: NCPCIWP
Page 4
Date: 1/28/2000
Date: 1/20/00

INDUSTRY INSPECTION CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
J I N I C l 0 1 0 12 l 0 14 12 17 1 01 / 20 // 00 ._±_l I S I 21 1.
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Trinity Manufacturing, Incorporated
2. Industry Address: P.O. Box 1519 Hamlet, NC 28345
3. Type of Industry/Product: Chemical / Chloropicrin, Bleach, and Aluminum Cleaner
4. Industry Contact: Keith Warbington / Karen Messana Title: Technical Manager / Safety Director
Phone: [phone] Ext. 227 / 111 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 Yes
E. Exit Interview Yes
Industrial Inspection Comments:
Filename: NCPCIWP
Page 5
Date: 1/28/2000