NC0044725_Pretreatment Compliance Inspection Report with NOV_20231026

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7022 2410 0003 3233 6622
Return Receipt Requested
October 26th, 2023
James Croke
Laurinburg Industrial WWTP
16701 Airport Rd
Maxton, NC 28364
SUBJECT: NOTICE OF VIOLATION, NOV-2023-PC-0530
Pretreatment Compliance Inspection Report
Laurinburg Industrial WWTP NPDES ANCO044725
Scotland Co.
Mr. Croke:
A Pretreatment Compliance Inspection (PCI) of the Laurinburg Industrial WWTP's Pretreatment Program
was conducted by Sharon Moran from this office on September 27, 2023, in conjunction with James Croke,
ORC and Pretreatment Coordinator of Laurinburg Industrial WWTP. The purpose of this PCI is to
determine the effectiveness of the pretreatment program by reviewing various aspects of the program,
which included files and records, industrial user inspections and monitoring data, data management
procedures and adherence to the Enforcement Response Plan.
Laurinburg Industrial WWTP is currently a 2 MGD permitted facility and has four (4) Significant Industrial
Users (SIU); Railroad Friction Products, Scotland Manufacturing Inc., Huvepharma, Inc., and Umicore
USA, Inc.. Three permit files were reviewed: Railroad Friction Products, Scotland Manufacturing Inc.,
Huvepharma, Inc.. A site visit was not conducted during this inspection.
This Pretreatment Compliance Inspection report indicated that the Laurinburg Industrial WWTP's
Pretreatment Program did not meet all requirements as outlined in 40 CFR 403.8(f)(1) and 15A NCAC
02H .0916.
The findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report. Please respond in writing to this office within 30 days of your receipt of this letter regarding your
plans or measures to be taken to address the following issues:
• As noted in the previous inspection form dated 7/14/2022, the contract with Wagram for
wastewater acceptance must be acquired.
• Contact your lab to ensure detection levels are correct.
• Meet with industry to establish proper Toxic Organic Management Plan and documentation.
• Sewer Use Ordinance must be signed by governing body and approved through the State.
• Enforcement Response Plan did not have approval letter from State.
D-E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301
NORTH cARouN^ 910.433.3300
D.P.__ m environmental anar�ir

Thank you for your continued support of the North Carolina Pretreatment Program. If you should have any
questions, please contact Sharon Moran at [phone] or at [e-mail].
Sincerely,
ADoc1uuSigned b^y::' • . .
I V AIM' b (A�VI.� l�
E4E1A9691DB248E...
Mark Brantley, Assistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche

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:
2. Control Authority Representative(s):
3. Title(s):
LMAC
James Croke
ORC, Pretreatment Coordinator
4. Last Inspection Date: 7/14/2022 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 14 14 17 12 1 _LJ
MM/DD/YY
19 127123 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users SIUs ?
4
8. Number of SIUs With No IUP, or With an Expired IUP?
4
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 ?
2
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 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?
EYES ❑ NO
BOD, TSS, Fecal
Dirty contact chamber
❑ YES ®NO
Limits: N/A
Reporting: N/A
dished: N/A
N/A
❑ 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: Wrong detection levels being reported for TSS, Cd, Cr, Cu, Silver, Chlorine, Sodium, and Cobalt.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

27
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP?
If yes, which ones? Eliminated: Added:
[—]YES ® NO
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)
4/6/21
® Yes ❑ No
12/27/17
® Yes ❑ No
Industrial Waste Survey IWS
10/12/18
❑ Yes ❑ No
11/15/18
® Yes ❑ No
10/1/23
Sewer Use Ordinance SUO
❑ Yes ❑ No
❑ Yes ❑ No
Enforcement Response Plan (EPP)
❑ Yes ❑ No
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/6/21
® Yes ❑ No
10/27/17
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Scotland Manufacturing
2. Railroad Friction
3. Huvepharma
30. IUP Number
1 005
002
007
31. Does File Contain Current Permit?
❑ Yes ®No
❑ Yes ®No
❑ Yes ®
No
32. Permit Expiration Date
4/16/16
4/16/21
4/16/21
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
433
N/A
439.27
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. []Yes []No
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
YesENo❑N/A
P11
❑Yes❑NoON/A
❑Yes❑NoEN/A
Organic Management Plan TOMP ?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No]1
® Yes ❑ No
® Yes ❑ No
1
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
EYes❑No❑N/A
®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
[_E7;;6To0N/A
®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No[D
❑Yes❑No®N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
11
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
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
®Yes❑No❑N/A
All Rc ortin Non-Com liance 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
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
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c ❑Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I
❑
Yes
®
No_jj
❑
Yes
®
No 11
❑
Yes
®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoON/A
❑Yes❑NoON/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No[D
❑Yes❑NoON/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
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
All permits for industries are currently expired.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 1 1 I I I I I I I 1
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone:
Title:
Fax:
❑Yes ® No ❑ Yes ®No ❑ Yes ®No
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:
Requirements: As noted in the previous inspection form, the contract with Wagram must be acquired, contact your lab to ensure detection
levels are correct, meet with industry to establish proper Toxic Organic Management Plan. Unsigned copy of Sewer Use Ordinance
maintained, no approval letter from State. Enforcement Response Plan did not have approval letter from State.
Recommendations: Please update contact information and signature sheets on Slug Control plans for industries.
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory M 'MISianed bv: UnSatisfactory
PCI COMPLETED BY: 41A ,. M 0 DATE:
Faye t 1fMkiWkial Office
M
10/27/2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NCO044725 I11 121 23/09/27 I17 18I D I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES Dermit Number)
09:30AM 23/09/27
23/08/01
Laurinburg Industrial WWTP
16701 Airport Rd
Exit Time/Date
Permit Expiration Date
Maxton NC 283646899
03:30PM 23/09/27
28/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
James Thomas Croke/ORC/910-318-8282/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Seth Andrew Hatchell,16701 Airport Rd Maxton NC 28364//910-844-5081/
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
DocuSigned by:
Sharon Moran 1 �I - DWR/FRO WQ/910-433-3300/ 10/27/2023
u,aV'Dln, l'VI.OV'GUII,
EsME17E499D6943D...
Signature of an utsQA9faviewer Agency/Office/Phone and Fax Numbers Date
Mark Brantl y MAA braW /R/Division of Water Quality/910-433-3300 Ext.727/ 10/27/2023
CA C1 AQA(
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO044725 I11 12I 23/09/27 117 18 U
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Laurinburg Industrial WWTP is currently a 2 MGD permitted facility and has four (4) Significant
Industrial Users (SIU); Railroad Friction Products, Scotland Manufacturing Inc., Huvepharma, Inc., and
Umicore USA, Inc.. Three permit files were reviewed: Railroad Friction Products, Scotland
Manufacturing Inc., Huvepharma, Inc.. A site visit was not conducted during this inspection.
The findings and comments noted during this inspection are provided in the enclosed copy of the
inspection report. Please respond in writing to this office within 30 days of your receipt of this letter
regarding your plans or measures to be taken to address the following issues:
• As noted in the previous inspection form dated 7/14/2022, the contract with Wagram for
wastewater acceptance must be acquired.
• Contact your lab to ensure detection levels are correct.
• Meet with industry to establish proper Toxic Organic Management Plan and documentation.
• Sewer Use Ordinance must be signed by governing body and approved through the State.
• Enforcement Response Plan did not have approval letter from State.
Page#

Permit: NC0044725
Inspection Date: 09/27/2023
Owner - Facility: Laurinburg Industrial WWTP
Inspection Type: Pretreatment Compliance
Yes No NA NE
Page#