NC0025445_Pretreatment Compliance Inspection_20180103

R
Water Resources
Environmental Quality
January 3, 2018
Lisa Osthues
Pretreatment Coordinator
City of Randleman
168 Nathan Dudley Road
Clinton, NC 28328
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Randleman
NPDES# NCO025445
Randolph County
Dear Ms. Osthues:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
On November 15, 2017 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski.
Ms. Lisa Osthues was present for the inspection. The purpose of this inspection was to determine the
effectiveness of the Town's pretreatment program, which includes reviewing the files, POTW plant
performance, industry monitoring data, and adherence to the enforcement response plan (ERP).
Background
This is a 1.745 MGD permitted facility. The City has two (2) Significant Industrial Users which are non -
categorical. The publicly owned treatment works (POTW) has had exceedances of lead. The source of this
constituent has been identified as residential piping (ductile iron). The city is surveying the residential
areas and will develop a remedial plan to eliminate the problem.
POTW Interview
There are no plant problems related to pretreatment issues and there are no NPDES permit limit or
monitoring violations recorded from July 2016 through October 2017 except for the lead mentioned above.
The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on May 9, 2017. The HWA was approved on
August 16, 2017. The next HWA is due on June 1, 2022.
The last Industrial Waste Survey (IWS) was submitted on December 20, 2017. The IWS was approved on
March 14, 2013. The next IWS was due on December 31, 2017. The survey was initiated by the POTW.
However, not all the surveys have been received. The POTW will submit the IWS when all survey
information has been collected.
The Sewer Use Ordinance (SUO) was approved on February 4, 2013.
The Enforcement Response Plan (ERP) was approved on June 10, 2009.
-�"l�lotbi C�l�pulr� .�
State of North Carolina I Environmental Quality
450 W Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone. [phone] FAX. [phone]

The Short Term Monitoring Plan (STMP) was approved on October 10, 2011.
STMP File Review
The Short Term Monitoring Plan (STMP) is being conducted at the proper locations and frequencies.
Industrial User Permit O[UTP) File Review
A review of the file for Commonwealth Hosiery (#0001) revealed that the monitoring data was well
organized and compliant.
A review of the file for Deep River Dyeing (#0004) revealed that the monitoring data was well organized
and compliant.
The slug control plans for Commonwealth Hosiery (#0001) was in good order.
The slug control plans for Deep River Dyeing (#0004) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Osthues implements the pretreatment program in
an excellent manner. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
a
�t j§herri V. Knight, PE
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: PERCS Unit — Monti Hassan
Central Files
WSRO Files

R` NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
"Vater Rew'lrc to
UIM011MOTlt QLA LEIt
BACKGROUND INFORMATION [Complete Prior To PCI: Review Proeram Info Database Sheets
1. Control Authority (POTW) Name: C1
2. Control Authority �'
Representative(s): �-
3 Title(s)- Cirg4 Ez - Cnendc- (�00 c8 {1 Y�SCh r
4 Last Inspection Date- Inspection Type (Check One): ❑ PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? Eg-fES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ❑-<O
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
1NIC10IoIQIElgIL,_
MM/DD/YY
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)9
8. Number of SIUs With No 1UP, or With an Expired IUP?
9. Number of SILTS Not Inspected By POTW in the Last Calendar Year?
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Penods9
12. Number of SlUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
13 Number of SIUs in SNC with Pretreatment Schedule?
6
14 Number of SIUs on Schedules
15. Current Number Of Categorical Industrial Users (CIUs)9
16. Number of CIUs in SNC9
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 )9
If Yes, How are these Problems Being Addressed9
19 Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods9 Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
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 El NO
YES El NO
rib �v nS cu i w
Limits
Reporting M a 14)L_
blished:
❑ YES NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMT Monitoring Being Conducted at Appropriate Locations and Frequencies? n YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring9 �',YES ❑ NO
24. Is LTMP/STMT Data Maintained in a Table or Equivalent9 &YES ❑ NO Is Table Adequate? ❑ YES ❑ NO
25. All LTMP/STMT effluent data reported on Discharge Monitoring Report? ,N 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 WO
If yes, which ones? Eliminated. Added:

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
w
their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info -
Program Element
Last Submittal
Date I In file?
Last Approval Date Next Due,
Date In file If Applicable
Headworks Analysis A
1 r? ErYesEj No
F Yes ❑ No (p 1
Industrial Waste Survey S
-10 & ❑ es ❑ No
[�] Yes ❑ No I- j
Sewer Use Ordinance (SUO)
U1 ®' Yes ❑ No
Yes ❑ No
Enforcement Response Plan (ERP)
Yes ❑ No
(� b [rY s ElNo
Long Term Monitoring Plan (LTMP)
es ❑ No
)� 0 es ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1 r^ s anw
2.'�& VQ C
3.
30 IUP Number v
-� 00
op "
31. Does File Contain Current Permit?
es ❑ No
es 0 No 11
❑ Yes ❑ No
32 Permit Expiration Date
3
a 3
33 Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
34 Does File Contain Permit Application Completed Within One Year Prior
❑ Yes RNo
es ❑ I
ElYes ❑ No
to Permit Issue Date?
C16, Tr,�n
35. Does File Contain an Inspection Completed Within Las. Calendar Years
es ❑ No
19 -yes ❑ N—o-11
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a MY -es ❑No
a es ❑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
❑Yes❑No
❑Yes❑No /A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
38 a. Does File Contain Original Permit Review Letter from the Division
a. es ❑No
a Lyes []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
MAI s ❑ Nos
❑ No
F
❑ Yes El No
its Sampling as Required b IUP, includingflow?
40 Does File Contain POTW Sampling Chain-Of-CustodyForms
Yes ❑ No
Yes El No7j
El Yes El No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Cilie No❑N/A
es❑No❑N/A
1
❑Yes❑No❑N/A
Sam ling as Required by IUP, including flow
11
41b During the Most Recent Seim -Annual Period, Did SIU submit all reports
s❑No❑N/A
es❑No❑N/A
❑Yes❑No❑N/A
on tnne9
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No❑ h<
❑Yes❑No
❑Yes❑No❑N/A
file mclueeprocess/dilution flows as Required by IUP?
42b For categorical IUs with Production based limits, does file include
-11
OYesONoRROA
❑Yes❑No /A
❑Yes❑No❑N/A
production rates and/or flows as Required by JUP?
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 Sam ling?
N2' ✓lam
N O
43b During the Most Recent Semi -Annual Period, Did the POTW Identify
0Yes0No01N7X
❑Yes❑No /
❑Yes❑No❑N/A
All Re ortinNon-Com fiance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a ❑Yes❑No[>B A
a ❑Yes❑Non WA
a ❑Yes❑No❑N/A
Monitoring Violations?
b Did Industry Resample and submit results to POTW Within 30 Days
b ❑Yes❑NomAt/A
b ❑Yes❑NoUNA
b ❑Yes❑No❑N/A
c If applicable, Did POTW resample within 30 days of becoming aware
c ❑Yes❑Nolg1eA
❑Yes❑NopPA
❑Yes❑No❑N/A
of SIU limit violations in the POTW's samplingof the SIU
c
c
46. Duringthe Most Recent Semi -Annual Period, Was the SIU in SNC?
I❑ Yes o
❑ YesKPKo11❑
Yes ❑ No
47 During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoOhf6A
❑Yes❑No /A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)
48 Does the File Contain PenaltyAssessment Notices?
❑Yes❑NopI�LA
❑Yes❑No /AI
❑Yes❑No❑N/A
49 Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEl
❑Yes❑No5R/
❑Yes❑No❑N/A
50 a Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoWN/A
a.❑Yes❑Nofi}Pd/A
a ❑Yes❑No❑N/A
b Is SILT in Compliance with Orders
b ❑Yes❑NogDUA
b ❑Yes❑Nodi/A
b ❑Yes❑No❑N/A
51 Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes No
❑Yes o
❑ Yes ❑ No
Requested Information For You?
NC DNR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

a �
,j FILE REVIEW COMMENTS:
T, i �aS`� cue C&Xv' rz:yA4�) S Co
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:
Phone:
Fax:
Title:
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: L p�� ��, t�S �2� �,. C e4c r-, i ,CA
— vk)'i It dev 040-P C r e fi o e u C.) ZSVN. -J
Requirements:
Recommendations:
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory Marginal UnSatisfaetory
PCI COMPLETED BY: DATE: 1 S
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