NC0028916_Pretreatment Compliance Inspection_20160701

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
" Secretary
WaterResources S. JAY ZIMMERMAN
ENVIRONMENTAL QUALITY
Director
July 1, 2016
RECEIVEDINCL IEC
JUL 0 7 2016
Joe Shields Water Quz itY
Pretreatment Coordinator Pet-mining Section
Town of Troy
444 North Main Street
Troy,NC 2737121
SUBJECT: Pretreatment Compliance Inspection (PCI)
Town of Troy WWTP
NPDES Permit#NCO028916
Montgomery County
Dear Mr. Shields:
Enclosed please find a copy of the Pretreatment Compliance Inspection Report from the
inspection conducted on June 21, 2016 by Trent Allen of the Fayetteville Regional Office. The
PCI report indicated that The Town of Troy WWTP met the pretreatment requirements as
outlined in 15A NCAC 2H .0900 for the Pretreatment Programs.
Please refer to the enclosed inspection report for additional observations and comments. If you
or your staff has any questions, please call me at 910-433-3336.
Sincerely,
Trent Allen
Assistant Regional Supervisor
Division of Water Resources
Water Quality Regional Operations Section
cc: PERCS Unit
FRO Pretreatment Files (TA)
State of North Carolina Environmental Quality I Water Resources
225 Green Street-Suite 7141 Fayetteville,North Carolina 28301-5043
910433-3300

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 15 1 3 1 NCO028916 111 12 16/06/21 17 18 I o I 191 G 1 201 I
2111111111111111111111111111111111111111 '1111 �6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA --Reserved-----
67 70 71 L1 I 72 I N I 731 1 174 751 1 1 1 1 1 1 �80
Section B: Facility Data
I t I I I %
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 10:OOAM 16/06/21 15/08/01
Troy WWTP
Exit Time/Date Permit Expiration Date
650 Glen Rd
01:OO13M 16/06/21 19/06/30
Troy NC 27371
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Donald Ray Freeman/ORC/910-220-0159/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Benny Ray Dennis,315 N Main St Troy NC 27371//910-572-7841/9105723663
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
Trent Allen '.�� FRO WQ//910-433-3300/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Be' d S H nson FRO WQ//910-433-3300 Ext.72( -711 I
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type (Cont. 1
31 NCO028916 I11 121 16/06/21 117 18 UP
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Wright Foods has changed over from an apple sauce process to a broth process.A new plant
manager was also hired, and most of the compliance problems at the WWTP have ceased. Floor
drains at the industry are now plugged during the processing and cleaning, and have improved permit
compliance. Mr. Shields does not think a slug plan is now needed.The DAF unit is operational, and is
in the process of major upgrades that should further help with compliance.At this time, the industry is
only operating on an as need basis with hopes of going 24/7 in the near future.Wright Foods new plant
manager has made great strides to improve the operating processes at the industry and the
pretreatment process.There was not an inspection conducted at the industry during the pretreatment
inspection, only a courtesy visit to see how things had improved.
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION(Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name:Town of Troy
2. Control Authority Representative(s):Joe Sheelds
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date:01/24/2014 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N �N I C 1 0 1 0 1 2 18 1 9 11 16 1 06 121 1 16 1 I P I l S L—L j
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 1 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 0 CIUS
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. 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 0 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 0 SNPS
16.Number of SIUs 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 NPDES Limits Violations? ®YES ❑ NO
If Yes, What are the Parameters and How are these Problems Being Addressed? BOD
Fecal
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 Valve at landfill was stuck
in the open position sending
Sludge Production,Etc.)? leachate to the WWTP. This
If Yes,How are these Problems Being Addressed? has been corrected.
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:0
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:0
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:0
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/A
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑ YES ® NO
Ones?
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
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1

27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes,which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

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 Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 02/02/2014 ® Yes❑ No 04/11/2014 ®Yes ❑ No 01/31/2019
Industrial Waste Survey IWS 01/06/2015 ® Yes❑ No 02/06/2015 ® Yes ❑ No 12/31/2019
Sewer Use Ordinance SUO 12/28/2012 ® Yes ❑ No 01/03/2013 ® Yes ❑ No_
Enforcement Response Plan(ERP) 12/08/2009 ®Yes ❑ No 12/21/2009 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 1 12/08/2009 ® Yes❑ No 12/21/2009 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Wright Foods 2. 3.
30. IUP Number 0003 1 ---�
31. Does File Contain Current Permit? ® Yes ❑ No ❑ Yes ❑ NoI ❑Yes ❑ No
32. Permit Expiration Date 08/01/2018
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 ❑Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No 11 ❑Yes ❑ No ❑Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan? a. ❑Yes NNo a. ❑Yes ❑No a. ❑Yes❑No
b.If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes NNo b. ❑Yes ❑No b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoNN/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. NYes[IN o a. ❑Yes ON 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 ❑Yes ElNo El ElNo
its Sampling as Required b g IUP, including flow?
10. Does File Contain POTW Sampling Chain-Of-Custody Forms? ® Yes ❑ No 11 ❑Yes ❑ I ❑Yes ❑ No
11. 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 by IUP,including flow? il
I lb.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?
12a. For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
12b.For categorical IUs with Production based limits,does file include ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
13a. During the Most Recent Semi-Annual Period, Did the POTW Identify F® Yes ❑ No ❑ Yes ❑ No ❑Yes ❑ No
All Limits Non-Compliance from Both POTW and SIU Sampling?
13b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
All ft ortin Non-Compliance from SIU Sampling?
14. 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 Days9 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.pYes❑No❑N/A c.pYes❑No❑N/A
16. During the Most Recent Semi-Annual Period, Was the SIU in SNC?; ❑ Yes ® No ❑ Yes ❑ No 1 ❑Yes ❑ No
17. During the Most Recent Semi-Annual Period, Was Enforcement Taken ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties,timing, tc.)?
18. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
19. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑NIA
50. a. Does the File Contain Any Current Enforcement Orders? Ro
❑Yes❑NoNN/A [b.0Yes[jNoEIN/A
.❑Yes❑No❑N/A a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order? 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 ❑Yes ❑ No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

FILE REVIEW COMMENTS:
At the time of the inspection,Wright Foods had changed over from an apple sauce process to a broth process.A new plant manager
was also hired, and most of the problems at the WWTP have improved. Floor drains at the industry are now plugged during the
processing and cleaning,and have improved permit compliance.Mr.Shields does not think a slug plan is now needed.The DAF unit is
operational, and is in the process of major upgrades that should further help with compliance. At this time, the industry is only
operating on a as need basis with hopes of going 24/7 in the near future.Wright Foods new plant manager has made great strides to
improve operating processes at the industry and the pretreatment process. There was not an inspection conducted at the industry
during the pretreatment inspection,only a courtesy visit to see how things had improved.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
I- NJ I l l I l l l l I l I I I L I J L S I 1?l
(DTIA) (TYPI) (INSP) (FACC)
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"four ❑ 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 ® NO
NOV: ❑ YES ® NO
QNCR: ❑YES ®NO
POTW Rating:
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 4

Satisfactory Marginal UnSatisfactory
PCI COMPLETED BY: Trent Allen DATE: June 21,2016
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 5