NC0037508_Compliance Report_20220725

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Connie Flowers
Laboratory Supervisor
Moore County WPCP
1094 Addor Rd.
Aberdeen, NC 28315
NORTH CAROLINA
Environmental Quality
July 25t", 2022
SUBJECT: Pretreatment Program Compliance Inspection Report
Moore County
NPDES#: NC00357508
Dear Ms. Flowers,
Enclosed please find a copy of the Pretreatment Compliance Inspection (PCI) form from the inspection
conducted on July 20t", 2022. The audit was conducted by Stephanie Zorio, an Environmental Specialist
from the North Carolina Division of Water Resources (DWR) Fayetteville Regional Office.
The findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled " Pretreatment Compliance Inspection".
Requirements and Recommendations:
• To reiterate from the audit, Erico will submit a TOMP for the next permit cycle (exp. 6/30/2023).
• Review the first set of results from Environment 1 to determine if they are using the proper low level
detection limits specified by the LTMP.
Comments:
• The Pretreatment Program files were well -organized and accessible to the inspector. Ms. Flowers was
highly competent and accommodating while answering questions during the inspection and does a
commendable job managing the Pretreatment Program along with her other duties.
• Moore Co. switched contact laboratories to Environment 1 from Meritech in June 2022.
• An updated LTMP was submitted to the Division on 10/22/21.
D_EQ`
North Carolina Department of Environmental Quality I Dtvlslon of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 I Fayetteville, North Carolina 28301
910.4333300

Thank you for your continued support of the Pretreatment Program. If you should have any questions, please
do not hesitate to contact Stephanie Zorio with the Water Quality Regional Operations Section in the
Fayetteville Regional Office at 910-433-3322 or via email at [e-mail].
ATTACHMENTS
Pretreatment Inspection Report
Cc: laserfiche
Sincerely,
—DocuSigned by:
A99704FAED5D494...
Dr. Stephanie Zorio, Environmental Specialist
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
DEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 I Fayetteville, North Carolina 28301
910.4333300

NNORTH CAROLINA DIVISION OF WATER RESOURCES
C
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: Moore Co. WPCF
2. Control Authority Representative(s): Connie Flowers
3. Title(s): Lab Supervisor
4. Last Inspection Date: Sept. 2021
Inspection Type (Check One): ❑ PCI ® Audit
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 ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number
NC0037508
MM/DD/YY
11/1/2016
7. Current Number Of Significant Industrial Users (SIUs)?
3
8. Number of SIUs With No IUP, or With an Expired IUP?
0
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. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
3
16. Number of CIUs in SNC?
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)
SNC for
SNC for
Not Pul
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?
I1 YES ❑ NO
BOD-facility continues
to rehabilitate sand
filters. A clarifier
also failed but is
being repaired.
❑ YES /1 NO
Limits: N/A
Reporting: N/A
lished: N/A
none
❑YES /1NO
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
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

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 Division Inspector, please verify
yourself! June 2021 DMR included all monitoring parameters for each sampling location at the facility.
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/17/19
0 Yes ❑ No
12/16/19
/1 Yes ❑ No
1/31/25
Industrial Waste Survey (IWS)
8/30/18
0 Yes ❑ No
9/7/18
/1 Yes ❑ No
9/1/23
Sewer Use Ordinance (SUO)
7/24/19
0 Yes ❑ No
8/22/19
/1 Yes ❑ No
Enforcement Response Plan (ERP)
12/3/19
0 Yes ❑ No
2/5/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/22/21
0 Yes ❑ No
*see comments
11 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Erico Incorporated
2. Southern Tool & Die
3. Thermal Metal Treating
30. IUP Number
A005
A010
A008
31. Does File Contain Current Permit?
II Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
32. Permit Expiration Date
6/30/23
10/31/24
6/30/25
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Al Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
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. •Yes ■ No
a. ►Yes ■No
b. •Yes ■ No
a. Yes •No
b. •Yes ■ No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes®No❑N/A
❑ Yes ENo❑N/A
®Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes •No
b.❑Yes❑No®N/A
a. Yes •No
b.❑Yes❑No®N/A
a. Yes •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?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
i1 Yes ❑ No
i1 Yes ❑ No
A Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
NYes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NoNN/A
❑ Yes ❑NoON/A
❑Yes❑NoNN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑NoON/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
®Yes❑No❑N/A
® Yes ❑No❑N/A
❑Yes❑NoON/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑ Yes ❑NoON/A
❑Yes❑NoON/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
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes®No❑N/A
b.❑Yes❑No®N/A
c.❑Yes❑NoDN/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes A No
❑ Yes I1 No
❑ Yes A 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
®Yes❑No❑N/A
®Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

48. Does the File Contain Penalty Assessment Notices?
49. Does The File Contain Proof Of Penalty Collection?
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
®Yes❑No❑N/A
®Yes❑No❑N/A
NYes❑No❑N/A
❑ Yes ❑NoON/A
❑ Yes ❑No®N/A
❑ Yes ❑NoON/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑ Yes /1 No
❑ Yes /1 No
❑ Yes /1 No
FILE REVIEW COMMENTS:
Erico:
• Permit was modified in 2020—removed POC that were removed from the LTMP, updated detection limits.
• EHS manager changed, need to send Moore Co. an updated spill control plan.
• Erico will submit a TOMP at the start of the next permit cycle.
• Erico usues Microbac as contract lab. Remind them to include temperature on pH samples.
Southern Tool & Die:
• Permit modified in 2021 including the same modified parameters as Erico..
• A TTO test was performed in 2019.
• They do not have a pretreatment system. Southern Tool has a contract with MEritech. Meritech performs periodic sampling with
their own equipment.
• Flow meter was relocated to an appropriate area. The result was a marked increase in accuracy of flow data that indicated flow
from Southern Tool was less than previously recorded (and subsequently was causing to violate daily limits).
Thermal Metal:
• COC issues discovered during audit in 2021 have been resolved. Technicians from Pace previously insisted that the facility staff
did not need to sign COC forms. Samples are now being properly relinquished by Thermal Metal staff.
• Permit was modified in 2020 including the same modified parameters as Erico.
• Thermal Metal has a TOMP. They performed a TTO test in 2019 because they did not submit their certification letter.
• Spill control plan was updated on 11/2021.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
11111111111111
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:
Phone: Fax:
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 ❑ NO
B. Plant Tour ❑ YES ❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

C. Pretreatment Tour ❑ YES ❑ NO
D. Sampling Review ❑ YES ❑ NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments:
• The Pretreatment Program files were well -organized and accessible to the inspector. Ms. Flowers was highly competent and
accommodating while answering questions during the inspection and does a commendable job managing the Pretreatment Program
along with her other duties.
• Moore Co. switched contact laboratories to Environment 1 from Meritech in June 2022.
• An updated LTMP was submitted to the Division on 10/22/21.
Requirements:
To reiterate from the audit, Erico will submit a TOMP for the next permit cycle (exp. 6/30/2023).
Recommendations:
Review the first set of results from Environment 1 to determine if they are using the proper low level detection limits specified by the LTMP.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory x Marginal UnSatisfactory
PCI COMPLETED BY: Stephanie Zorio DATE: 7/20/2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4