NC0086550_Pretreatment Inspection_20091231

.4t7A,
NCDENR.
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 31, 2009
Mr. H. Blake Proctor
Town Manager
Town of Fairmont
PO Box 248
Fairmont, NC 28340
Subject: Pretreatment Compliance Inspection (PCI)
Town of Fairmont
NPDES Permit # NC0086550
Robeson County
Dear Mr. Proctor,
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report
for the inspection that was conducted at the Fairmont Town Hall on November 5, 2009
with Nadine Blackwell (Pretreatment Coordinator, United Water), Johnny Britt (Fairmont
WWTP ORC), and Kevin Taylor (Fairmont WWTP operator) to review the Fairmont
Pretreatment Program records. During the PCI, Harger Lightening Protection Grounding
Equipment, Inc. (IUP #001) was inspected, and Phil Huffman, Harger Purchasing
Manager, provided a tour of Harger's pretreatment facilities and the production plant.
The PCI report indicated that, on the day of this inspection, the Fairmont WWTP
appeared to meet the pretreatment requirements as outlined in 15 A NCAC 2H..0904 for
Pretreatment Programs.
The 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].
[Dale Lopez
Environmental Specialist
Enclosure: Pretreatment Compliance Inspection (PCI) Report
cc: Nadine Blackwell, United Water
Dana Folley, PERCS — Pretreatment
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] l FAX: [phone] d Customer Service: 1-877-623-6748
Interne: www.ncwaterquality.org
Dee Freeman
Secretary
NorC]a Caroli..na
Naturally
An Equal Opportunity 1 Affirmative Action Employer

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION (Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: _ Town of Fairmont WWTP
2. Control Authority Representative(s): Nadine Blackwell
3. Title(s): PT Coordinator
4. Last Inspection Date: New Program Inspection Type (Check One): ❑ PCI ❑ Audit
N/A1
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ei NO
N/AI
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY
N.1
J NJCI0 1018161515 10 1 J 11 1051 091
(DTIA)
Inspec.Type
J PI
(TYPI)
Inspector
J s
(INSP)
Fac. Type
1 1 1
(FACC)
7. Current Number Of Significant Industrial Users (SIUs)?
1
SIUS
8. Current Number Of Categorical Industrial Users (CIUs)?
1
CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? Inspected 09/24/09
0
10. Number of SlUs Not Sampled By POTW in the Last Calendar Year?
Not sampled yet; Harger began discharging process on September 14, 2009
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?
19. Which Industries have been in SNC for Limits or Reporting 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?
❑ YES NO
❑ YES I4 NO
SNC for Limits:
SNC for Reporting:
Not Published:
0
0
0
0
❑ YES NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ❑ YES ®.NO
Is Table Adequate? ❑ YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ❑ YES ❑ NO
26. LINO to 23 - 26, list violations
27. Should any Pollutants of Concem be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
N/A, will be in the future
Will in the future
❑ NO
N/A, will be in the future
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their tiles, complete with supporting documents and copy ofPERCS Approva Letter, and dates consistent with Pro{grati� Info:
Program Element
Last Submittal
Date In tile?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
❑ Yes ❑ No
10/05/2009
/i4 Yes ❑ No
Industrial Waste Survey (IWS)
❑ Yes ❑ No
Will be sent by
November 30,
2009
❑ Yes ❑ No
Sewer Use Ordinance (SUO)
❑ Yes ❑ No
10/28/09 sent
to
PERCS
❑ Yes ❑ No
Enforcement Response Plan (ERP)
❑ Yes [ No
10/28/09 sent
to
PERCS
❑ Yes ❑ No
Long Term Monitoring Plan (STMP)
❑ Yes ❑ No
08/26/09
f:1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
Harger Lightening & Grounding Equipment
30. IUP Number
001
31. Does File Contain Current Permit?
/ZI Yes ❑ No
32. Permit Expiration Date
03/01/2014
33. Categorical Standard Applied (LE. 40 CFR, Etc.) Or N/A
40 CFR 468 (h, j, k, m)
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
35. Does, File Contain an Inspection Completed Within Last Calendar Year?
i1 Yes ❑ No (09/24/2009)
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. •Yes @No
b. ►SYes ■No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑NoION/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►SYes ■No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
❑ Yes ►1 No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑ Yes ❑ No NE
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
4l b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
42a. For categorical lUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by .IUP?
❑Yes❑No®N/A
42b. For categorical lUs with Production based limits, does file include
production rates and/or flows as Required by IU.P?
®Yes❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
I1 Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW W :Identify
All Reporting Non -Compliance from SIU Sampling?
®Yes❑No❑N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
a.❑Yes❑No®N/A The CIU was aware of reporting req.
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes I1 No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
NC DWQ Pretreatment Compliance Inspection (PCI) Form
Updated 7/25/07 Page 2

48.
Does the File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
49.
Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
50.
a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
51.
Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes No
FILE REVIEW COMMENTS:
1. The IWS was not completed, but will be completed by the end of November 2009.
2. STMP: The POTW aeration basin was sampled during the week of this PCI; the POTW Influent and the
Effluent were planned to be sampled on a quarterly basis. The sludge to disposal sampling and
analyses will be performed next year.
3. Harger's Slug Control Plan was in the process.
4. The Town of Fairmont's WWTP routinely received wastewater from the following locations:
• Town of Fairmont,
• Fair Bluff,
• Boardman,
Poctorville,
• Orrum Middle School
• (maybe by the end of November 2009) Cerro Gordo.
NC DWQ Pretreatment;Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

4
INDUSTRY INSPECTION PCS CODING:
Trans.Code
L NJ
Main Program Permit Number MM/DD/YY
Inspec.Type Inspector Fac. Type
JNIC101018J615►5101 1111051091 J I 1 J S [ J 2 1
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected:
2. Industry Address:
Harger Lightening & Grounding
12779 Highway 130 East Fairmont, NC 28340
3. Type of Industry/Product: Manufacturing of lightningprotection and grounding equipment
4. Industry Contact: Rich Macary/Phil Huffman Title Operations Manager/Purchasing Manager
Phone: [phone] and (910) 628- 5284
Fax: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? `1 YES ❑ NO
On the day of this PCI visit to Harger, the PT, Coordinator did not perform an inspection, the reason being that
one was performed on 09/24/2009.
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ❑ YES .❑ NO
B. Plant Tour ❑ YES ❑ NO -
C. Pretreatment Tour ❑ YES ❑ NO
D. Sampling Review ❑ YES ❑ NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments:
There was 1 to 2 micrometers of tin coated onto the copper wire.
2 gauge copper wire was annealed and drawn down to 16 gauge wire.
Reagents: 93% sulfuric acid, Liquichlor 12.5% (bleach), 50% NaOH (caustic).
10 employees at the CIU, for lightening protection & grounding: residential and commercial interwoven into
the building. Copper, tin, and aluminum were the main metals that were used at the CIU.
40 CFR 468: a copper forming operation only. Aluminum/copper alloy processed were heated, stretched, anneal,
spooling, and electroplated. The water rinse was in the electroplating process only. Harger's daily flow limit =
5,000 GPD. The wastewater flow was measured by a propeller type flow meter. The flow meter was calibrated
by LT Technologies [phone]. Thy oor tna i;apl = E eclitoite it ghat t} .CiLlir l7h aflofi-
'iTrtettr-because it was not originally installed correctly; and, during the week efore t sPCC the error ifillation
was corrected.
The bath flowed to pH adjustment for the precipitation of metals, then to filtration (copper and tin), then
backwash into the effluent discharge tank (in which a grab .sample was taken for the effluent 001 discharge)
NC DWQ Pretreatment C mplirnce Inspection (PCI) Form Upilatcd 7.'25107 Page 4

ti
PCI COMPLETED BY: 4-4
OVERALL SUMMARY AND COMMENTS:
Comments: The SUO and the ERP were submitted to PERCS and were being processed for approval.
Requirements:
Recommendations:
As according to the proposed time table that the Town submitted to the PERCS unit:
Please submit 1) the Industrial Waste Survey (IWS) by November 30, 2009,
2) the Headworks Analysis by August 31, 2010.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES I NO
POTW Rating:
Satisfactory V 1V�arginal Unsatisfactory
ATE: 12/31/2009
Reviewed by : �cile/nhat. "
Date: 1/ `4 // D
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 5

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 15I. 3.1 N00086550 111 .121 09/11/05 117
Type Inspector Fac Type
1810 191 SI 201 I
• •
IIII IIII III66
Remarks
21IIII I11111111111111111111.III IIIIIIII
Inspection Work Days Facility Self -Monitoring Evaluation Rating • B1 QA - - -- Reserved----------
67I 2.0 169 701 31 •711 I 721 N I 731 1174 751 1 I 1 1 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Fairmont Regional WWTP ,
Off' US Hwy 74
Fairmont NC 28340
Entry Time/Date
10:30 AM 09/11/05
Permit Effective Date
09/11/01
Exit Time/Date
03:00 PM' 09/11/05
Permit Expiration Date
14/07/31
Name(s) of Onsite Representative(s)fTitles(s)/Phone and Fax Number(s)
///
Johnny J Britt/ORC/910-628-0064/ .
Other Facility Data
Name, Address of Responsible OfficialfTitle/Phone and Fax Number
Johnny J Britt,PO Box 248 Fairmont NC Contacted
283400248/Superintendent/910-628-0064/ 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 Sigikture(s) of Inspector(s) ( Agency/Office/Phone and Fax Numbers Date
Dale Lopez �! (` FRO WQ//910-433-3300 Ext.712/ / d� i0
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

31
NPDES
NC0086550
111 121
yr/mo/day
09/11/05
Inspection Type
17. 18I PI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Pretreatment Compliance Inspection Report for the inspection that was
conducted at the Fairmont Town Hall on November 5, 2009 with Nadine Blackwell (Pretreatment
Coordinator, United Water), Johnny Britt (Fairmont_WWTP ORC), and Kevin Taylor (Fairmont WIMP
operator) to review the Fairmont Pretreatment Program records. During the PCI, Harger Lightening
Protection Grounding Equipment, Inc. (IUP #001) was inspected, and Phil Huffman, Harger Purchasing
Manager, provided a tour of Harger's pretreatment facilities and the production plant. The PCI report
indicated that, on the day of this inspection, the Fairmont WWTP appeared to meet the pretreatment
requirements as outlined in 15 A NCAC 2H..0904 for Pretreatment Programs. The SUO and the ERP
were submitted to PERCS and were being processed for approval. Recommendations: As according to the
proposed time table that the Town submitted to the PERCS unit, please submit: 1) the Industrial Waste
Survey (IWS) by November 30, 2009, 2) the Headworks Analysis by August 31, 2010.
The 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].
Page # 2