NC0025909_Pretreatment Compliance Inspection Report_20240910

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

September 10, 2024

Doug Barrick
Town of Rutherfordton
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Rutherfordton WWTP
NPDES WW Permit No. NC0025909
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection (PCI) of the
Town of Rutherfordton’s Pretreatment Program on 8/22/2024. The PCI was conducted to verify that the
program is being managed and maintained in compliance with all Pretreatment regulations. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report", as well as the PCI form. There were no significant issues or findings noted
during the inspection and therefore, a response to this inspection report is not required.

If you should have any questions, please do not hesitate to contact me at 828-296-4667 or via email at
[e-mail].

Sincerely,

Lauren Armeni, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Compliance Inspection Report (BIMS), PCI Form

Ec: Nadine Blackwell (Pretreatment Coordinator, Veolia)
Philip Reynolds (WWTP ORC, Veolia)
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
EPA
United States Environmental Protection Agency
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 Type Inspector Fac Type
1 N 52 NC0025909 24/08/22 P S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Rutherfordton WWTP
NC Hwy 221
Rutherfordton NC 28139
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/08/22 22/12/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Phillip E Reynolds/ORC/828-287-2141/
Other Facility Data
11:00AM 24/08/22 27/07/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Doug Barrick,129 N Main St Rutherfordton NC 28139/Town Manager/828-287-3520/Contacted
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
Lauren E Armeni DWR/ARO WQ/828-296-4500/
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
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
9/11/2024
9/11/2024
NPDES yr/mo/day
24/08/22
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, with the Asheville Regional Office, conducted a Pretreatment Compliance Inspection
(PCI) of the Town of Rutherfordton's Pretreatment Program on August 22, 2024. Phillip Reynolds
(WWTP ORC) and Alexis Cabrera (WWTP BORC) were present during the inspection.
Overall, the program appears to be in compliance with Federal and State Pretreatment requirements.
The Rutherfordton Pretreatment Program has one Significant Industrial User (SIU), which is a
Categorical Industrial User (CIU), Aallied Die Casting. Paperwork was readily accessible and
organized. See the attached PCI form for file review comments and recommendations.
NC0025909 17 (Cont.)
Page#2
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
Permit:NC0025909
Inspection Date:08/22/2024
Owner - Facility:
Inspection Type:
Rutherfordton WWTP
Pretreatment Compliance
Yes No NA NE
Page#3
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Rutherfordton WWTP
2. Control Authority Representative(s): Phillip Reynolds and Alexis Cabrera
3. Title(s): ORC and BORC
4. Last Inspection Date: 09/18/23 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 MM/DD/YY
| N | C | 0 | 0 | 2 | 5 | 9 | 0 | 9 | | 08 | 22 | 24 |

7. Current Number Of Significant Industrial Users (SIUs)? 1
8. Number of SIUs With No IUP, or With an Expired IUP ?0 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? N/A
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)? 1
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?
YES NO

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?
YES NO
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 Limits: N/A – no flow to WWTP, didn’t
sample
SNC for Reporting: Same
Not Published: N/A
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?

None

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
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 Inspector, please verify yourself!
26. If NO to 23 - 26, list violations See file review comments below.

Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
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) 07/15/20 Yes No Not yet
approved
Yes No 2025
Industrial Waste Survey (IWS) N/A Yes No N/A Yes No N/A – see
below
Sewer Use Ordinance (SUO) 04/15/19 Yes No 07/01/19 Yes No N/A
Enforcement Response Plan (ERP) 04/15/19 Yes No 07/01/19 Yes No N/A
Short Term Monitoring Plan (STMP) 10/16/23 Yes No 09/05/24 Yes No N/A
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Aallied Die Casting 2. 3.
30. IUP Number 0003
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 12/31/28
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 464.14
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
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?
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 No 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?
Yes No
N/A
Yes No Yes No
40. Does File Contain POTW Sampling Chain -Of-Custody Forms? Yes No
N/A
Yes No 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 Yes 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 No N/A Yes No N/A Yes No N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A 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?
Yes No
N/A
Yes No Yes No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A 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

b.Yes No N/A

c.Yes No N/A
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 No N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No
N/A
Yes No Yes 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
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
49. Does The File Contain Proof Of Penalty Collect ion? Yes No N/A Yes No N/A 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
a.Yes No N/A
b.Yes No N/A
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 Yes No Yes No

FILE REVIEW COMMENTS:
During the inspection, Mr. Reynolds indicated that Aallied Die Casting has not discharged to the WWTP since January 18, 2023;
therefore, no sampling has been needed. The industry does not typically discharge because they have a water recycling system. Mr.
Reynolds stated that they still periodically check the manhole where flow from Aallied Die Casting goes to the WWTP to verify that
they are not discharging.

STMP sampling started during the second quarter of 2024 and will conclude the first quarter of 2025. After a review of the STMP
laboratory report from the April 2024 sampling, it was noted that the LDL for Total Suspended Residue was 2.5 mg/L, but accor ding
to the STMP it should be 2 mg/L. LDLs were not listed for some parameters, so it is recommended to have the lab list all LDLs on
the laboratory reports, and be sure to resend the STMP to all labs that do the analyses.

The IWS was last conducted in 2024. Per the “End of the 2023 Calendar Year” letter sent out to local Pretreatment Program staff,
Industrial Waste Surveys will no longer need to be submitted to the Division every five years, starting in 2024. POTWs should
maintain an IWS that may be requested by the Division for review at any time. The IWS was reviewed during this inspection and
appeared to be adequate.

The last SIU inspection conducted in December 2023 by the Town was reviewed, and it was noted that the inspection reports moving
forward should indicate whether or not the industry discharged to the WWTP that year, and if not, that sampling was not required.

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| | | | | | | | | | | | | |

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:
No industry inspection was conducted.
Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

OVERALL SUMMARY AND COMMENTS:
Comments: ______________________________________________________________________________________________
__________________________________________________________________________________________________________
Requirements: ______________________________________________________________________________________________
__________________________________________________________________________________________________________
Recommendations: It is recommended to have the labs list all LDLs on the laboratory reports and to resend the STMP to all labs
that do the analyses.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Lauren Armeni DATE: 08/22/24 _______________________________

Docusign Envelope ID: 09F589DC-05FC-4B6C-A76E-AC6620BA2BF3