NC0026441_Compliance Inspection_20180111

Water Resources
ENVIRONMENTAL QUALITY
January 11, 2018
Mr Chris McCorquodale
Wastewater Superintendent
Town of Siler City
PO Box 769
Siler City, NC 27344
Subject- Pretreatment Compliance Inspection
Town of Siler City
NPDES Permit No NCO026441
Chatham County
Dear Mr. McCorquodale:
Govei not
MICHAEL S REGAN
Secretary
LINDA CULPEPPER
Interim Director
RECEIVED/DENR/DWR
JAN 16 2018
Water Resources
Permitting Section
On December 14, 2017, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Inspection (PCI) of Town of Siler City's pretreatment program The assistance given by
Mr Terry Green, Director of Public Works and Utilities, and you, was greatly appreciated. The
inspection report is attached. Findings during the inspection were as follows
There is only one Significant Industrial Users (SIUs) discharging to the POTW, which is not a
Categorical Industrial User (CIU) It was noted that the SIU was in Significant Non -Compliance
(SNC) for TSS and BOD violations for the last two semi-annual penods An Industrial User
Pretreatment Permit (IUP) to Mount Aire was issued and submitted to the Division for review.
Mount Aire is expected to discharge to the POTW at the beginning of 2019
2. The review of Long Tenn Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and detection limits since last inspection.
3 A review of the files containing the pretreatment program elements was conducted. All files
were up to date, except the Industrial Waste Survey (IWS). IWS update was originally due on
September 29, 2017. The due date to be extended to December 28, 2017 by the Division upon
the Town's request. At the time of inspection, it appeared another extension of the due date was
needed
4. The Industrial User Pretreatment Pen -nit (NP) file review included Brookwood Farms, hic.
(Pen -nit No. 003) All files were available for review During the most recent semi-annual
period, the POTW identified one BOD and one TSS violation from POTW sampling The POTW
Division of Watei Resoluces, Raleigh Regional Office, Water Quality Operations Section http //postal ncdent orghvcbhvq/aps
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone [phone]
Location 3800 Barrett Drive, Raleigh, NC 27609 Fax [phone]

issued Notices of Non-compliance (NOCs) to address both violations as required by the
Enforcement Response Plan.
Thank you for your continued support of t -_-ie Pretreatment Program If you have questions regarding to
the attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or email•
cheng zhang@ncdenr gov)
Dr;Slcy,
/7ith
Dannv S
Regional Supervisor
Raleigh Regional Office
Enclosure Town of Siler City PCI Inspection Forn
CC Vivien Zhong, PERCS Unit
Central Files
Cheng Zhang, RRO

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORIMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1 Control Authority (POTW) Name Town of Siler City
2 Control Authority Representative(s) Terry Green; Chris McCorguodale
3 Title(s) Director of Public Works & Utilities; Wastewater Superintendent
4 Last Inspection Date August 10, 2016 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 Mets ❑ YES [:]NO
ICIS CODING
Main Program Permit Number NIM/DD/YY
N I C 1 0 10 12161414111 112114117
7 Current Number Of Significant Industrial Users (SIUs)?
1
8 Number of SIUs With No IUP, or With an Expired IUP?
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 Years
0
11 Number of SIUs In SNC For Limits Violations During Either of the Last 2Semi-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)9
0
16 Number of CIUs in SNC?
0
POTW INTERVIEW
17 Since the Last PCI, has the POTW had any NPDES Limits Violations9
If Yes, What are the Parameters and How are these Problems Being Addressed9
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 Addressed?
19 Which Industries have been in SNC for Limits or Reporting durmg SNC for
either of the Last 2 Semi -Annual Periods9 Not Been Published for SNC fol
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?
®YES ❑ NO
BOD (sample hose contamination)
Cadmium (sources unknown)
❑ YES ® NO
Limits None
Reporting None
dished None
None
[:]YES ® NO
LTMP/STMP FILE REVIEW:
22 Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies9 ® YES ❑ NO
23 Are Correct Detection Levels being used for all LTMP/STMP Monitormg9 ® 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
27 Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP9 ❑ YES ® NO
If yes, which ones? Eliminated Added
NC DWR Pietreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files, verify POTW has copy of Program Element in
I
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)
2/8/2016
® Yes ❑ No
5/6/2016
® Yes ❑ No
9/1/2020
Industrial Waste Survey (IWS)
12/12/2012
® Yes ❑ No
12/12/2012
® Yes ❑ No
12/28/2017
Sewer Use Ordinance (SUO)
12/18/2012
® Yes ❑ No
1/2/2013
® Yes ❑ No
® Yes ❑ No
Enforcement Response Plan (ERP)
1 9/17/2008
® Yes ❑ No
11/19/2008
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 4/25/2016
® Yes ❑ No
5/6/2016
® Yes ❑ No
a ®Yes ON
INDUSTRIAL USER PERMIT (IUP) FIFE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29 User Name IF
1 Brookwood Farms
2
3
30 IUP Number
003--�
31 Does File Contain Current Permit?
® Yes ❑ No
32 Permit Expiration Date
12/31/2020
33 Categorical Standard Applied (I E 40 CFR, Etc) Or N/A
N/A
34 Does File Costain Permit Application Completed Within One Year Prior
® Yes ❑ No
to Permit Issue Date?
35 Does File Contain an Inspection Completed Within Last Calendar Year9
® Yes ❑ No
36 a Does the File Contain a Slug/Spill Control Plan
a ®Yes ON
b If No, is One Needed? (See Inspection Form from POTW)
b ❑Yes ON
37 For 40 CFR 4- 3 and 433 TTO Certification, Does File Contain a Toxic
❑Ycs❑No[K
Organic Management Plan (TOMP)9
38 a Does File Contain Original Permit Review Letter fro--ri the Division
a ®Yes ON
b All Issues Resolved9
b ❑Yes❑No❑N/A
39 During the Most Recent Serm-Annual Period, Did the FOTW Complete
®Yes ❑ No
its Sampling as Required by IUP, including flow?
40 Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
41 Durmg the Moat Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b During the Most Recent Semi -Annual Pei iod, Did SIU submit all reports
®Yes❑No❑N/A
on tune9
42a For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
file include process/dilution flows as Required by ILT9
42b For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
pioduction rates and/or flows as Required by IUP9
43a During the Mcst Recent Semi-Ainnual Period, Did the POTW Identify
®Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b During the Mcst Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
All Rorting Non -Compliance from SIU Sampling
ep?
44 a Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a ❑Yes❑No®N/A
Monitoring Violations
b Did Industry Resample and submit results to POTW Within 30 Days
b ®Yes❑No❑N/A
c If applicable, Did POTW iesample within 30 days of boconning aware
c ❑Yes®No❑N/A
of SIU limit violations in the POTW's sampling of the SIU
46 During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
47 Duiing the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc )9
48 Does the File Ccntam Penalty Assessment Notices9
❑Yes❑No®N/A
49 Does The File Contain Proof Of Penalty Collection
❑Yes❑No®N/A
50 a Does the File Contain Any Current Enforcement Order -,9
a ❑Ycs❑No®N/A
b Is SN in Compliance with Order?
b ❑Yes❑No®N/A
51 Did the POTW Repiesentative Have Difficulty in Obtaining Any of This
❑ Yes ®No
Requested Information For Your
NC DWR Pieheatment Compliance Inspection (PCI) Form Updatecl December 2016 Page 2

FILE REVIEW COMMENTS:
43a - One TSS and one BOD violation were identified from POTW sampling.
44b — SIU resampled within 30days as required by the POTW.
47 - The POTW issued two NOVs for the above violations.
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 Equivalent9 ❑ 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 The program is well managed.
Requirements None
Recommendations None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhan2, Raleigh Regional Office DATE: December 14, 2017
NC DWR Pietreatment Compliance Inspection (PCI) Form Updated Decembei 2016 Page 3