NC0025071_Pretreatment Compliance Inspection_20180131

Water Resources
Environmental Quality
January 31, 2018
Chris Powell
Pretreatment Coordinator
City of Eden
P.O. Box 70
Eden, NC 27289
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Eden
NPDES# NCO025071
Rockingham County
Dear Mr. Powell:
ROY COOPER
Govenror
MICHAEL S REGAN
Secretary
LINDA CULPEPPER
Intel im Director
RECEIVE®/DENR/DWR
FEB 0 5 2018
Water Resources
Permitting Section
On December 13, 2017 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski
and Paul DiMatteo of the Winston-Salem Regional Office. Mr. Chris Powell and Ms. Melinda Ward were
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 8.89 MGD permitted facility. The City has three (3) Significant Industrial Users two (2) of which
are categorical. The publicly owned treatment works (POTW) has had no exceedances of permitted
constituents.
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 November 2017. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on March 13, 2017. The HWA was approved on
August 10, 2017 The next HWA is due on April 21, 2022.
The last Industrial Waste Survey (IWS) was submitted on September 21, 2015. The IWS was approved on
October 15, 2015. The next IWS is due on December 1, 2020.
The Sewer Use Ordinance (SUO) was approved on December 14, 2012
The Enforcement Response Plan (ERP) was approved on August 18, 2015.
The Long Term Monitoring Plan (LTMP) was approved on October 25, 2017.
State of North Carolina I Environmental Quality
450 W Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone. [phone] FAX, 336-776-9797

LTAI P File Review
The Long Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for Mohawk/Kerestan (#0005) revealed that the monitoring data was well organized
and compliant.
A review of the file for Weil -McLain (#0012) revealed that the monitoring data was well organized and
compliant.
A review of the file for Duke Energy (#0013) revealed that the monitoring data was well organized and
compliant.
The slug control plans for Mohawk/Kerestan (#0005) was in good order.
The slug control plans for Weil -McLain (#0012) was in good order.
The slug control plans for Duke Energy (#0013) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Powell implements the pretreatment program in
an excellent manner. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
fro%Sherri 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

' NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
.raterRc:sourres
enwvor.MFNI nL avnca rr
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
2.
3.
4.
5.
6.
Control Authority (POTW) Name:
Control Authority Representative(s):
Title(s): ,' (' ¢„
Last Inspection Date
Inspection Type (Check One): ❑ PCI []­Xudit
Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ YES ❑ NO
Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES a<O
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
I NIQI0 Io I Js`—IC7I-7 I I I
MM/DD/YY
Ca I Is I 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)?
8. Number of SIUs With No IUP, or With an Expired IUP?
10
9. Number, of SIUs Not Inspected By POTW in the Last Calendar Year?
(3
"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 Periods?
V
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?
14. Number of SIUs on Schedules?
15. Current Number Of Categorical Industrial Users (CIUs)?
FF�
16 Number of C1Us in SNC?
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.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive S1Us in SNC) Not Put
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 MNO
❑ YES QNO
Limits -
Reporting: nJ©n
ilished:
(I 0y, e-
❑ YES V] NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? 8 YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? N YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ❑ YES ❑ NO Is Table Adequate? ,KJ YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report?,25YES ❑ 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 J`NO
If yes, which ones? Eliminated: Added:
TTr1 "AIM rDr'T\ L`...... TT—,4.+.A TI—S— IMA 13— 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW – Please review POTW files, verify POTW has copy of Program E
their files, complete with supporting documents and copy of PERCS Annroval Letter, and dates consistent with Prosram Info:
Program Element
Last Submittal
Date In file?
Last Approval Date Next Due,
Date In file If Applicable
Headworks Analysis A
Yes ❑ No
2 1101Z1 Yes ❑ No
Industrial Waste Survey IWS
a J Yes ❑ No
1,4 tM Yes ❑ No J01i
Sewer Use Ordinance SUO)
4 J Yes ❑ No
JJA
Yes ❑ No
Enforcement Response Plan RP
�C] Yes ❑ No
�' (' ❑ Yes No
Long Term Monitoring Plan (LTMP)
•�)d° Yes ❑ No
j15 fD -1 ' Yes ❑ No
INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTIO
29. User Name
lea ww
2.� _
3. MC
mu i
30. IUP Number
Li ;() Q IF
No
01
31. Does File Contain Current Permit?
Yes ❑ No
E. Yes ❑ No 11
N Yes ❑ No
32. Permit Expiration Date
a fQ6 I liz
FJJ
3
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
33 e t
34. Does File Contain Permit Application Completed Within One Year Prior
0 Yes ❑ No
4] Yes *No
. ,Yes ❑ No
to Permit Issue Date?
35 Does File Contain an Inspection Completed Within Last Calendar Year?
I N Yes ❑ Rol
N Yes ❑ No
Yes ❑ No
36 a. Does the File Contain a Slug/Spill Control Plan?
a.'tE Yes ❑No
a. gYes ❑No
aXYes ❑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®N/A
❑Yes❑NogN/A
' Yes❑No❑N/A
Organic Management Plan TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. NYes []No
a. jg.Yes []No
a.XYes ❑No
b. All Issues Resolved?
b ❑Yes❑No /A
b ❑Yes❑NoE1N/A
b ❑Yes❑No1KN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
Eq Yes ❑ No
N Yes ❑ No
Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Yes ❑ No
Yes ❑ No
Yes ❑ No
41 During the Most Recent Semi -Annual Period, Did the SILT Complete its
>0Yes0No❑N/1
KYes❑No❑N/A
PkYes❑No❑N/A
Sampling as Required b IUP, including flow?
1-
41b. During the Most Recent Semi -Annual Period, Did SILT submit all reports
XYes❑No❑N/A
AYesONoDN/A
Yes❑No❑N/A
on time
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoXI
❑Yes❑No
❑Yes❑NS4N/A
Me includeprocess/dilution flows as Required by IUP?
42b. For categorical lUs with Production based limits, does file include
❑Yes❑No� /A
❑Yes❑NoMN/A
❑Yes❑NgJON/A
production rates and/or flows as Required b IUP?
43a During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ Yes No
❑ Yes P No
❑ Yes' No
All Limits Non -Compliance from Both POTW and SIU Sampling?
r
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes o❑N/A
Wes❑No❑N/A
❑Yes No❑N/A
All Re ortin -Compliance from SU Sampling?
hMe
44 a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑ 4o�
� ��
a.X'Yes❑No❑N/A
a.❑Yes❑NoIRN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b ❑Yes❑NoRN/Ab
NYes❑MDN/A
b ❑Yes❑No)4N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c ❑Yes❑No /A
of SIU limit violations in the POTW's sampling of the SIU?
c)�'Yes❑No❑N/A
c ❑Yes❑N%N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes No 11
[:]Yes ®) No
❑ Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No /A
❑Yes
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
`No❑N/A❑Yes❑NoWN/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No /A
❑Yes❑NoCiN/A
❑Yes❑No N/A
49. Does The File Contain Proof Of Penalty Collection?
0Yes❑No0N/A
❑Yes❑NoE N/A
I ❑Yes❑No N/A
50. a. Does the File Contain Any Current Enforcement Orders9
a ❑Yes❑Nd�kN/A
a.❑Yes❑No1*;/A
a.❑Yes❑No /A
b. Is SIU in Compliance with Order?
b ❑Yes❑Nd N/A
b ❑Yes❑No /Ab
❑Yes❑No /A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
1:1 es 91No
❑ Yes N No
❑ Yes � No
Requested Information For You?
11
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

&E REVIEW COMMENTS:
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry insnected:
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:
Requirements:
Recommendations.
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory_Marginal UnSatisfactory
PCI COMPLETED BY: +A DATE: l I
r
NC DWR Pretreatment Comnliance Inspection (PCI) Form Updated December 2016 Page 3