NC0026441_Pretreatment Compliance Inspection_20230531

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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
May 31, 2023
Hank Raper, Town Manager
Town of Siler City
PO Box 769
Siler City, NC 27344
Subject: Pretreatment Compliance Inspection
Town of Siler City
NPDES Permit No. NCO026441
Chatham County
Dear Mr. Raper:
On May 5, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Inspection (PCI) of Town of Siler City's pretreatment program. The assistance given by
Mr. Chris McCorquodale, Director of Public Works & Utilities, and Ms. Brittany York, Wastewater
Superintendent, was greatly appreciated. The inspection report is attached. Findings during the
inspection were as follows:
1. The Town has two Significant Industrial Users (SIUs) discharging to the POTW, neither is a
Categorical Industrial User (CIU). It was noted that both SIUs were in Significant Non -
Compliance (SNC) for the last two semi-annual periods.
2. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and detection limits since the last inspection.
3. A review of the files containing the pretreatment program elements was conducted. All files
were up to date. Update of Headworks Analysis (HWA) was submitted to the Division on April
16, 2021. Update of Industrial Waste Survey (IWS) was submitted to the Division on March 3,
2023. Update of LTMP was submitted to the Division on April 28, 2023. It was found during
inspection that the LTMP needs to be updated by using the most recent DWR PQLs. The POTW
submitted revised LTMP again on May 31, 2023.
4. The Industrial User Pretreatment Permit (IUP) file review included Brookwood Farms, Inc.
(Permit No. 003) and Mountaire Farms (Permit No. 004). All files were available for review.
During the most recent semi-annual period:
Brookwood Farms had three TN violations and one flow violation and was in SNC for total
nitrogen limit violations, the POTW issued five Notices of Violation (NOVs, including one
for SNC) to Brookwood Farms. Brookwood Farms failed to notify the POTW of all self -
monitoring violations within 24 hours of awareness of the violations, which is a reporting
violation.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
n�,Mo E,Amnm W1 Q­1K,

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Mountaire Farms had numerous ammonia, BOD, total nitrogen, and total phosphorous
violations, and should be in SNC for monthly average violations for ammonia, BOD, and
total nitrogen. The POTW failed to identify Mountaire's SNC status at the time of
inspection. The POTW issued a NOV for Mountaire Farms' SNC during the second 6-
month period of 2022 on May 10, 2023. The POTW addressed Mountaire Farms' limit
violations by issuing six NOVs and assessed 6 civil penalties (total amount of $532,500).
5. It was noted during the file review that there are significant discrepancies between POTW
and Mountaire Farms self -monitoring results. The POTW recognizes the issue and needs to
continue to investigate what causes such discrepancies.
Thank you for your continued support of the Pretreatment Program. If you have questions regarding the
attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or email:
cheng. zhang@ncdenr. gov).
Sincerely,
DocuSigned by:
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9C4F04ECDE594A1...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): Town of Siler City PCI Form
Cc: Laserfiche
Chris McCorquodale and Brittany York, Town of Siler City (Electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
enpn .mo EnWromm�nfal nual

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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Siler City
2. Control Authority Representative(s): Chris McCorguodale, Brittany York
3. Title(s): Director of Public Works & Utilities; Wastewater Superintendent
4. Last Inspection Date: September 29, 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:
ICIS CODING
Main Program Permit Number
I N I C 1 0 10 12161414111
Are Milestone Dates Being Met? ❑ YES [—]NO
MM/DD/YY
1051051231
7. Current Number Of Significant Industrial Users (SIUs)?
2
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?
2
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 ?
0
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 SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Put
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
Multiple violations for cadmium,
BOD, ammonia, TSS, and fecal
® YES [-]NO
Limits: Both SIU
Reporting: None
Ilished: Mountaire 2" d 6-mon period
None
❑ YES ®NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
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 Division Inspector, please verify yourself!
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: silver
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

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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)
4/16/2021
® Yes ❑ No
5/6/2016
® Yes ❑ No
9/1/2020
Industrial Waste Survey IWS
3/2/2023
® Yes ❑ No
5/15/2018
® Yes ❑ No
2/28/2023
Sewer Use Ordinance SUO
12/18/2012
® Yes ❑ No
1/2/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
6/2/2020
® Yes ❑ No
9/3/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 4/28/2023
® Yes ❑ No
5/6/2016
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
F. Brookwood Farms
2. Mountaire Farms
3.
30. IUP Number
003
004
31. Does File Contain Current Permit?
® Yes
❑
I ® Yes ❑ No
32. Permit Expiration Date
12/31/202
1 12/31/2025
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ NoI
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes []No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes []No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑NoON/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes
❑ No
® Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
❑Yes®No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑No®N/A
All Reporting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes®No❑N/A
a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.®Yes❑No❑N/A
b.❑Yes❑No®N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.®Yes❑No❑N/A
c.®Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
®
Yes
❑
No
®
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
®Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
®Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
®Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
ll
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

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FILE REVIEW COMMENTS:
18 — As required by the SOC the POTW entered, the Town is in the process to update the IUPs to better control the impact from SIUs,
including modifying Mountaire's IUP with a compliance schedule and planning to issue IUP to the Town's Water Treatment
Plant.
43a — Brookwood Farms had three TN violations and one flow violations; Mountaire Farms had numerous ammonia, BOD, TN, and
TP violations, and should be in SNC for monthly average violations for ammonia nitrogen, BOD, and total nitrogen, the POTW
failed to identify Mountaire's SNC status. The POTW issued a NOV to Mountaire Farms for the SNC during the second 6-month
period of 2022 on May 10, 2023.
44a — Brookwood Farms failed to notify the POTW of all self -monitoring violations within 24 hours.
47 — The POTW issued 5 NOVs to Brookwood Farms (including one SNC NOV) and 6 NOVs to Mountaire Farms' limit violations.
48 & 49 — The POTW assessed 6 civil penalties to Mountaire Farms for limit violations.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
l 1 I I l
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
C. Pretreatment Tour
❑ YES ❑ NO
D. Sampling Review
❑ YES ❑ NO
E. Exit Interview
❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: The POTW was on top of taking enforcement actions against Mountaire's violations. Improvement is needed in compliance
judgement (SNC).
Requirements: Request Brookwood Farms to notify the POTW of self -monitoring violations with 24 hours. Modify and resubmit LTMP
by adding silver as POC and using the Division's updated POLs (submitted on 5/31/2023).
Recommendations: Continue to investigate why there are significant discrepancies between POTW and Mountaire Farms self -
monitoring.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ® UnSatisfactory ❑
PCI COMPLETED BY: Chem Zhang, Raleigh Regional Office DATE: May 5, 2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3