NC0021491_Pretreatment Compliance Inspection_20170126

Water Resources
Environmental Quality
January 26, 2017
Ms. Christine Bralley, Town Manager
Town of Mocksville
171 Clement Street
Mocksville, NC 27028
SUBJECT: Pretreatment Compliance Inspection
Town of Mocksville
NPDES Permit #NC0021491
Davie County
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
JAN 31 2017
Water Quality
Permitting Section
A Pretreatment Compliance Inspection (PCI) was performed by April Norton of the Division of Water
Resources (Division) Winston-Salem Regional Office, on the subject facility on January 25, 2017. , The
Pretreatment Coordinator, Heather Adams, was present for the inspection. The purpose of this inspection was
to determine the effectiveness of the pretreatment program, which included a review of pretreatment program
elements, publicly owned treatment works (POTW) plant performance, industry monitoring data, and
adherence to the enforcement response plan (ERP).
The Town currently has one (1) Significant Industrial Users (SIU), which is not categorical. The user name
is House of Raeford, and the industrial user permit number is 0004. The SIU was not in significant non-
compliance during the previous semi-annual period. However, there were permit limit violations during
January 2016 (two separate violations occurred), February 2016, March 2016, April 2016, and June 2016. All
violations were the result of biochemical oxygen demand limit exceedances; three Notice of Violations were
issued. An equalization basin has since been installed. The limit exceedances do not appear to have impacted
the POTW.
Program Elements Review
1. Headworks Analysis (HWA) ' — The purpose of the HWA is to determine the maximum allowable
headworks loading, the uncontrollable loading, and the maximum allowable industrial loading (MAIL)
the publically owned treatment works (POTW) can receive from its SIU's without failing a NPDES
permit limit, interference with the POTW, restricting the beneficial use of sludge, or impacting worker
safety and health. The HWA was approved on February 19, 2016 and is due for renewal on September
30', 2020. There were no errors noted with the HWA at the time of the inspection.
2. Industrial Waste Survey (IWS) — The purpose of the IWS is to identify new and existing Industrial Users
and their pollutants of concern that require permitting either as SIU's or Non-SIU's. The IWS was
approved on December 19,"2014 and is due for renewal on December 31, 2019. There were no errors
noted with the IWS at the time of the inspection.
3. Sewer Use Ordinance (SUO) — The purpose of the SUO is to develop, and enact a SUO that provides the
local government the legal authority to implement the pretreatment program and protects the POTW,
POTW workers, the public, surface waters of the State and sludge.
State of North Carolina I Environmental Quality
450 West Hanes Mill Road, Suite 300 J Winston-Salem, North Carolina 27105
336-776-9800

The SUO was approved on June 11, 2014, an update is not required unless significant changes take place.
4. Enforcement Response Plan (ERP) — The ERP is created by the POTW, and is used to provide fair and
equitable treatment in initial and escalating enforcement actions. The ERP was last approved on June 15,
2010. No errors were noted with the ERP during the inspection.
5. Short Term Monitoring Plan (STMP) — The purpose of the STMP is to gather POTW data for completion
of a site-specific headworks analysis. No errors were noted with the STMP during the inspection.
The next Pretreatment Annual Report (PAR) is due March 1, 2017. The pretreatment program is implemented
in an excellent manner. Your efforts are appreciated.
Please refer to the attached inspection report for further detail. If you have any questions, please contact April
Norton at [phone].
Sincerely,
Ar�herri V Knight, PE, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: WSRO Files
Central Files
Monti-Hassan—;PERCS-Unit--�

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
1. Control Authority (POTW) Name: Town of Mocksville
2. Control Authority Representative(s): Heather Adams
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 07 /24 /2015 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection or 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector
n N I C 10 0 12 11 14_ 9 1 Ol 25.17 ® S❑
Fac. Type
(FAC
(DTIA) (TYPI(INSP)
7. Current Number Of Significant Industrial Users (SIUs)? 1
SLUS
8. Current Number Of Categorical Industrial Users (CIUs)?
0
CIUS
9. Number of SIUs Not Inspected B POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled B POTW in the Last Calendar Year?
0
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 DuringEither of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUs In SNC For Limits Violations DuringEither of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SILTS In SNC For Both Reporting and Limits Violations During Either of the Last 2
0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any POTW Permit Limits Violations? QSI Yes U No
If Yes, What are the Parameters and How are these Problems Being Addressed? October 2016 - toxicity limit
violation - ass/fail - fail
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial [:]Yes ® No
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 during either of the Last 2 Semi- SNC for Limits: N/A
Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: N/A
2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: N/A
(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? N/A21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which - []Yes ® No
Ones?
LTMP/STMP FILE REVIEW:
22. Is the LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes El No
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®Yes [-]No
24. Is the LTMP/STMP Data Maintained in a Table or Equivalent? ®Yes El No Is the Table Adequate? ❑ Yes [:1 No
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO DWQ Inspector, please verify!
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to the LTMP/STMP? El Yes Z No
If yes, which ones? Eliminated: Added:

28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Pr `!
their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Pro 7/
Program Element
Last Approval
Date In file
Date Next Dur' -
Headworks Analysis A
2-19-2016
Yes ❑ No
9-30-2020
Industrial Waste Survey S
12-9-2014
® Yes ❑ No
12-31-2019
Sewer Use Ordinance SUO
6/11/2014
® Yes ❑ No
Enforcement Response Plan RP
6/15/2010
® Yes ❑ No
to Permit Issue Date?
Long Term Monitoring Plan (LTMP)
7/01/10
® Yes ❑ No
® Yes [:1 N1
o
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
1
29. User Name
1. House of Raeford 2. 11
3.
30. IUP Number
0004
31. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No ❑ Yes ❑ No
32. Permit Expiration Date
2 A/ 22
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑No
❑ Yes ❑ No 17es ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes [:1 N1
o
❑Yes El No ❑Yes El 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 I
b. ❑Yes ❑No
I b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No❑N/A ❑Yes❑No❑N/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❑NoNN/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❑N/A
❑Yes❑No❑N/A ❑Yes❑No❑N/A
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custodies?
I ®Yes❑No❑N/A
❑ Yes ❑No❑N/A ❑Yes❑No❑N/A
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required b IUP, includingflow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical lUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoON/A❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoRN/A
❑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❑N/A
❑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❑NOON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Re 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
of SIU limit violations in the POTW's sampling of the SIU ?
.
e❑Yes❑No®N/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
❑ Yes ❑ No
11 ❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTWs ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
11 ❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
11 ❑Yes❑No❑
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a. ❑Yes ®No
a. ❑Yes ❑No
Yes []No
[][]Yes
JFb
Is SIU in Compliance with Order?
b. []Yes ®No
b. ❑Yes ❑No
❑No
50. Did the PQTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑Yes ❑ No
[:] No
Requested
Requested Information For You?

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type
F ❑
(DTIA) (TYPI)
1. Industry Inspected: N/A
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:
Requirements:
Recommendations:
NOD: ❑ Yes 0 No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑
Unsatisfactory ❑
PCI COMPLETED BY: April Norton DATE: January 26, 2017
Inspector
Fac. Type
0
0
(INSP)
(FACC)