NC0044725_Pretreatment Audit_20060428

Michael F. Easley, Governor
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
April 28, 2006
Ms. Jo Ann Gentry
Pretreatment Coordinator
Laurinburg-Maxton Airport Commission (LMAC)
PO Box 3,1
Lauring, NC 28352
SUBJECT: Pretreatment Audit Report
Laurinburg-Maxton Airport Commission (LMAC)
NPDES Permit #: NC0044725
Scotland County
Dear Ms. Gentry: .
The Fayetteville Regional Office of the Division of Water Quality (DWQ) and the
PERCS - Pretreatmen Unit in Raleigh have completed the report for the Pretreatmen t
Audit held at the. Laurinburg-Maxton Airport Commission facility in Laurinburg on April
12, 2006.. Jon Risgaard of the PERCS - Pretreatmen Unit in Raleigh and I'n et with you
and Gary Arnett (ORC) to review_LMAC's Pretreatment Program Documents; and we
later inspected Railroad Friction (IUP#002). .
Please review.the enclosed report.. Ifyou have any questions or comments,
please contact me at [phone], or Jon Risgaard at (919).733-5083, ext. 580..,
Dale Lopez
Environmental Specia
JR/DL:DL/d1
Enclosures:. Pretreatment Audit Report
cc: Central Files, with enclosure
Jon Risgaard, PERCS — PT 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
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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: _LMAC
2. Control Authority Representative(s):._JoAnn Gentry, Office Administrator, Gary Arnett — Superintendent of Airport Commission
3. Title(s):
4. Address of POTW:
Mailing PO Box 31
City _Laurinburg Zip Code : 28353
Phone Number 910-844-5081
5. Audit Date 4 / 12 _ / 2006
6. Last Inspection Date: _5 / 25 / 2006_ Inspection Type (Circle One
Fax Number 844-9681
udit
7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems?
If Yes, Explain.
Some fecal, TSS, BOD violations in late 2005, not related to Pretreatment.
9. Is POTW under an Order That Includes Pretreatment Conditions? Y
Order Type and Number: Are Mi estone Dates Being Met? Yes / No
Parameters Covered Under Order
PCS (WENDB)Coding
Trans.Code Main Program Permit Number 'MM/DD/YY Insp'ec.Type -Inspector . Fac.Type
L J LN_I_C_LOJ-0J_4_L4J_7J_2_I_51 05/_12_/ 06_ I G _I I 11 I
(DTIA) ' (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users (SIUS)? 4 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
0
0
0
NOIN
15. 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).
16. Number of SIUs with No IUP, or with an Expired IUP
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
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
Filename: LMAC Audit 04-12-06
Page 1
Revised: 06/30/98
0
0
0
0
0
0
PSNC
MSNC
SNIN

J ULIl S VV.1 1.1uf.V 1.11V SVlfV... L.t,.
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headworks Analysis (HWA)
8/27/01
4/30/06
Industrial Waste Survey (IWS)
2/3/04
7/30/08
Sewer Use Ordinance (SUO)
6/4/97
6/1/07 — Changed from 12/1/06)
Enforcement Response Plan (ERP)
10/1/96
LMAC should review and update as
needed.
Long Term Monitoring Plan (LTMP)
9/23/96
LMAC should review and update as
needed.
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? Ye
If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Yes / N
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 / N
If yes, Explain.
24. Date of Last SUO Adoption by Local Council / / LMAC is required, to have a signed version on file with
Pretreatment records.
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. o
If no, POTW .must send copy within 30 days. Recom ded that copy of the ERP is sent with renewed IUPs
27. you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudications, improper enforcement, etc.)? Yes
If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order: None
Resources
29. Please Rate the Following:
=1 incanararrnn,
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ..
S
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
S
Access to Operable Sampling
Equipment
S
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
Computer Equipment (Hardware and
Software)
S
Filename: LMAC Audit 04-12-06
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Revised: 06/30/98

Yes No Explain Yes or No. WWTF LTMP data gatherea by unarms ana mamtamea my w w i r auu rreLreaLu.eu.,•
ata is maintained in Excel by pretreatment.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Sampling costs are recovered.
Public Perception/ Participation
32. ere any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
o If yes, Explain. Loss of flow and industry has decreased revenue.
33. Has any one from the public ever requested to review pretreatment program files? Ye
If yes, Explain procedure. If no, How would the request be addressed? Information public record and would be made
available. Go through supervisor or commission and asked to request in writing.
34. Doe = POTW have a procedure in place that addresses requests by an industry for certain information to remain confidential?
Ye' / No If yes, Explain. Discussed and LMAC will avoid confidential information, but will set aside locked file to hold any
that t be required.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment?
At least 1/quarter and usually more often. Regular phone calls.
36. Is the public notified about changes in the SUO or Local Limits? Y
37. Were all industries in SNC published in the last notice
Permitting (Industrial Waste Survey -MS)
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?) Review of permit application, Federal regs, HWA, and information
provided from PERCs unit.
39. Does the POTW receive waste from any groundwater remediations (petroleum, CERCLA) or landfill leachate? Y
If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
40. Does the POTW accept waste by (circle if applicable)
situations.
Dedicated Pipe Will accept septic waste in emergency
41. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Prior approval with sampling results.
42. How does the POTW allocate its loadings to industries? Circle One
1.) Uniform Limits Historical Industry Nee. 3.) By Surch.:e 4.) Categorical Limits 5 Other..
Explain Other:
43. Review copies of current allocation tables for each WWTP. Are there any over allocations? Y
If yes, What parameters are over allocated?
It is recommended that LMAC review the permit limits for Cobalt (RR friction), and Cu, Sulfate, Germanium
(Umicore) to determine if these limits are still applicable.
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 % Try to maintain 10% bu
Filename: LMAC Audit 04-12-06
Page 3
Revised: 06/30/98
ill go down to 5%.

4V. nab ULG rV 1 'V GAF1G'IVI1l.l. 1 may t,v,
If yes, Explain.
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): Industry History, Permit Application,
Process Description, Inspection, POTW NPDES permit
48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
Industry samples. quarterly, POTW samples 1/6 months unless violations occur
Permit Compliance
49. Does the POTW currently have "or during the past year had any permits under adjudication? Ye
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. Records of compliance judgment are adequate.
51. Does the POTW use the Division's model inspection form or equivalent.
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 No `
If no, Explain. None are required, but some already have one. Those with slug plan have submittedo the POTW.
N
53. What criteria are used to determine if a slug control plan is needed? Potential to harm WWTF, Federal / State Requirements
54. What criteria does the POTW use to review a submitted slug control plan? Proper containment, and contact information
55. How does the POTW decide where the sample point for an SIU should be located? Process water prior to mixing with domestic
or non -regulated process waters.
56. Has the POTW established a procedure to ensure - : epresentative samples will be taken by the POTW or SIU each time?
(example: swirling the sample bucket uniformly No
If yes, Explain. LMAC has supervised IUP samp and is very particular.
57. Who performs sample analysis for the POTW for
Metals TBL
Conventional Parameters _TBL
Organics TBL
58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Forms were filled completely.
Long Term Monitoring Plan (LTMP) and Headworks Analysis (HWA)
59. Is LIMP maintained in a table.op o
Review Data and Explain. Remi hat all LTMP data must be included in the DMRs
60. Do you complete your own headworks analysis (HWA) Ye
If no, Who completes your HWA? Hobbs Upchurch & Associates (Mark Lacy) Phone L910,_692_-- 5616
Filename: LMAC Audit 04-12-06
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Revised: 06/30/98

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
5.) Resolve over allocation
62. In general, what is the most limiting criteria of your HWA? AII, but mostly Sludge quality
1.) Inhibition 2.) Pass Through
63. Do you see any way to increase your loadings in the future (Example: obtaining more land for sludge disposal)? Y
Explain. None needed at this time.
3.) Other
6.) 5 year expiration
Summary
64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Looking for new employee to learn pretreatment responsibilities.
Filename: LMAC Audit.04-12-06
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Revised: 06/30/98

Recommendations from the last PCI (May 25, 2005):
1. Recommend that the POTW send letters to all SIUs that requests that they send the POTW the monthly
flows:
2. Recommend that the POTW either stamp or write the date that the POTW receives information, correspondence,"
laboratory results; etc.
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STATUS: COMPLETE
STATUS: INCOMPLETE, POTW intends to in the future
Requirement from the last PCI (May 25, 2005):
1. The Headworks Analysis (HWA) should be sent to the PT Unit by 04/30/06.
STATUS: COMPLETE
Filename: LMAC Audit 04-12-06
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Revised: 06/30/98

Audit SUMMARY AND COMMENTS:
1. The flows on the 2005 PAR, the IDSF for Railroad Friction were listed as 3 and 4 for the two 6 month periods. It is suggested
that since the IUP requires that daily flows be monitored, and it appears that they are, then include the number of data points in
the IDSF for the next Pretreatment Annual Report, due by March 1, 2006.
2. The Notice of Violation sent to Railroad Friction (dated 04/05/06) concerned a copper limit violation on a sample that was
collected on March 23, 2005 and one that was collected on November 16, 2005. The NOV stated that the copper limit was
0.115 lbs/D, but the IUP indicated that the limit was 0.026 lbs/D. This NOV was very late for the sample that was collected
on March 23, 2005.
3. The LMAC pretreatment program continues to be a well -organized and efficient program. The Divisions thanks LMAC for the
preparations they took to have their files in good order and ready for review.
Requirements (# = questions number) (#24) Maintain a signed version of the SUO on file with Pretreatment records. (#59) all
LTMP effluent data must be included in the DMRs,
Recommendations: Program Elements — The ERP and LTMP were last updated in 1996, it is recommended that LMAC
review and revise as needed. (#26) - send a copy of the ERP with renewed IUPs. (# 43) - It is recommended that LMAC
review the permit limits for Cobalt (RR friction), and Cu, Sulfate, Germanium (Umicore) to determine if these limits are
still applicable. During the inspection it was noted that all of the flow data was not reported on the Industrial Data
Summary Form (IDSF) in the 2005 Pretreatment Annual Report (PAR). All flow monitoring resultsmust be judged for
complicane and should be included on the IDSF form, not just the flows associated with the pollutant sampling events.
Flow does not have to be judged for SNC, but repeat violations should be considered by the commission, and proper
actions to reduce minimize violations should occur.
NOD: YES
NOV: YES
QNCR: YES
POTW Rating:
NO
NO�
Satisfactory Marginal UnSatisfactory
Audit COMPLETED BY: Jon Risgaard (PERCS Unit) and Dale Lop
ez
4/12/0.6
Filename: LMAC Audit 04-12-06
Page 7
Revised: 06/30/98

INDUSTRY.INSPECTION PCS CODING:
Trans.Code Main Program Permit Number
1 N1 1NIC1010 [4 14 17 12 15 1
MM/DD/YY
5 112 106 1
(DTIA)
Inspec.Type
(TYPI)
Inspector Fac. Type
l S l l 2 l
(1NSP)
(FACC)
1. Industry Inspected: RR Friction Products
2. Industry Address: PO Box 1349 Laurinburg NC 28352
3. Type of Industry/Product: RR Brakes
Title:
4. Industry Contact: s Alan Chavis
Phone:
5. Does the POTW Use the Division Model Inspection Form or Equivalent?
Fax:
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? YES
Comments:
A. Initial Interview
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments:
North Carolina Pretreatment Audit Form
Page 8

r
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 (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
.1 I NI 2 151 31NC0044725 111 121 04/04/12 117
Type Inspector Fac Type
18I GI 191 SI 201 I
.
I -'III • I I I I I I I I I I I I66
Remarks
21L I I I I I I I I I I I I I I I I I I I I 1 I I I. I I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 3.0 169 701 31 71I I 72I NI 73I I •I 74 75I I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Laurinburg Industrial WWTP
NCSR 1434
Maxton NC 28364
Entry Time/Date
10:00 AM 04/04/12
Permit Effective Date
00/03/01
Exit Time/Date
03:00 PM 04/04/12
Permit Expiration Date
04/07/31 '
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Garry T Arnett/ORC/910-844-5081/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Paul G Davis,PO Box 31 Laurinburg NC 28353//910-844-5081/9108449681
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) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dale Lopez FRO WQ//910-433-3300 Ext.712/
Signature,of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NC0044725 111 12, 04/04/12 117 181
2
1
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
1.) The flows on the 2005 PAR, the IDSF for Railroad Friction were listed as 3 and 4 for the two 6-month
periods. It is suggested that since the IUP requires that daily flows be monitored, and it appears that they
are, then include the number of data points in the IDSF for the next PAR, due by March 1, 2007. 2.) The
NOV sent to Railroad Friction (dated 04/05/06) concerned a copper limit violation on a sample that was
collected on March 23, 2005, and one that was collected on November 16, 2005. The NOV stated that the
copper limit was 0.115 Ibs/D, but the IUP indicated that the limit was 0.026 lbs/D. This NOV was very late
for the sample that was collected on March 23, 2005.. 3.) The LMAC pretreatment program continues to be
a well -organized and efficient program. This office thanks LMAC for the preparations they took to have
their files in good order and ready for review. Requirement: Maintain a signed version of the SUO on file
with PT records. All LTMP effluent data must be included in the DMRs. Recomendations: Program
Elements - The ERP and LTMP were last updated in 1996, it is recommended that LMAC review and revise
as needed. Send a copy of the ERP with the renewed IUPs. It is recommended that LMAC review the
permit limits for Cobalt (RR Friction), and Copper, Sulfate, Germanium (Umicore)to determine if these limits
are still applicable. During the inspection, it was noted that all of the flow data was not reported on the
Industrial Data Summary Form (IDSF) in the 2005 PAR. All flow monitoring results must be judged for
compliance and shouold be included on the IDSF form, not just the flows associated with the pollutant'
sampling events. Flow does not have to be judged for SNC, but repeat violations should be considered by
the commission, and proper actions to reduce minimize violations should occur.
Page # 2