NC0020354_Failure to Submit Monitoring Report_20010614

�QF WAT�RP Michael Easley
\O G Governor
t cor William G Ross, Jr . Secretary
> North Carolina Department of Environment and Natural Resources
Q 'C Kerr T Stevens, Director
Division of Water Quality
June 14, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED }000 5'30 0C)C) a ao y ooag
MR. HUGH MONTGOMERY
TOWN MANAGER
TOWN OF PITTSBORO
PO BOX 759
PITTSBORO NC 27312
Subject: NOTICE OF DEFICIENCY —
Failure to Submit Short Term Monitoring Plan
Failure to Submit Proper Industrial User Pretreatment Permit Information
Pretreatment Unit Review of POTW Program Files
Town of Pittsboro (NPDES # NC0020354)*
Chatham County
Dear Mr. Montgomery:
The Pretreatment Unit of the Division of Water Quality has performed a review of the
Pretreatment Program files for the Town of Pittsboro. The review indicates the POTW is in
violation for the following items:
1. Failure to respond to Division letters regarding the POTW's Industrial User Pretreatment
Permit (IUP) for Hydro Tube South. The Division's August 17, 2000, letter (copy attached)
required a response by October 30, 2000. The POTW was sent reminder letter dated March
23, 2001, (copy attached) establishing a new due date of April 15, 2001. No response has
been received to date.
2. Failure to submit a Short Term Monitoring Plan (STMP) to the Division for review and
approval. The Division's June 30, 2000, letter (copy attached) required a response by
December 1, 2000. The POTW was sent reminder letter dated March 23, 2001, (copy
attached) establishing a new due date of April 15, 2001. No response has been received to
date.
You are directed to respond in writing no later than July 15, 2001, to the Pretreatment Unit, with
a copy to Ken Schuster of the Division's Raleigh Regional Office, as to the cause of the above
listed violations, actions the POTW has and/or will take to resolve the violations, and actions the
POTW has and/or will take to ensure that future violations will not occur.
You are further directed to include a STMP and the required response on the HydroTube South
IUP in your response by July 15, 2001.
Be advised that NCGS 143-215.6(a) provides that any violation of permit conditions may be
subject to a civil penalty not to exceed $10,000 per day per violation.
NC—DENR, DWQ, PRETREATMENT UNIT Telephone: [phone] Fax: [phone] ►in
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer NCMENR
Website: http://h2o.enr.state.nc.us/Pretreat/index.html 50% recycled/10% post -consumer paper

If you have any questions or comments, please contact me at [phone], ext. 522, Dana ;
Rees Folley of the Pretreatment staff at ext. 523 [email:[e-mail]], or Dale Lopez
of the Division's Fayetteville Regional Office at [phone].
Sincerely,
Tom S. Poe
Pretreatment Unit Supervisor
drf/pittsboromusc.NOD missed due dates
enclosures August 17, 2000, Industrial User Pretreatment Permit (IUP) Review letter
March 23, 2001, POTW Program Files Review letter
June 30, 2000, Headworks Analysis (HWA) Review letter
March 23, 2001, Headworks Analysis (HWA) Review letter
cc with enclosures:
Mr Wally Jenkins, Director Of Water Resources, Town Of Ptttsboro
- -Central File's
Bill Reid, Point Source Branch Supervisor
DRF, Pretreatment Unit
Ken Schuster/Pretreatment Files, Raleigh Regional Office

�O� 'w r, j F/9 MlLhael F Eagle,
O QG Governor
7 William G Ross. Jr , Secretary
North Carolina Department of Environment and Natural Resources
Kerr T Stevens, Director
Division of Water Qualitv
March 23, 2001
MR. WALLY JENKINS
DIRECTOR OF WATER RESOURCES
TOWN OF NORTH WILKESBORO
PO BOX 759
PITTSBORO NC 27312
Subject: Pretreatment Unit Review of the Headworks Analysis (HWA)
Town of Pittsboro (NPDES # NC0020354)
Chatham County
Dear Mr. Jenkins:
The Pretreatment Unit of the Division of Water Quality has reviewed the Headworks Analysis
(HWA) for the Town of Pittsboro. This HWA was received by the Division on February 16.
2001
The review indicates that more information is needed to deterrmne if the HWA meets the
minimum requirements of 15A NCAC 2H .0900 and 40 CFR 403.
In order for the Division to complete its review of the HWA, you are required to submit the
information outlined below by April 15, 2001. Examples and descriptions of some of the
following items are in the Comprehensive Guidance for North Carolina Pretreatment Programs
(Comprehensive Guide). It would be helpful to us if your resubmission included a disc or email
copy of any HWA and supporting spreadsheets.
1. BOD: The HWA provides documentation of Oxygen Demand capabilities using 240
mg/l BOD and 35 mg/l TKNI . The Division would accept this documentation to
support an MAHL for BOD of 1501.2 lbs/day based on Design (0.7 MGD x 5.34 x
240 mg/1). Please advise the Division if this is what the POTW wants, or provide
alternative computations and/or documentation.
2. TSS: The HWA does not directly discuss a design influent criteria for TSS. The
Division will continue with the previously approved MARL of 7112 lbs/day based on
Passthrough. Please advise the Division if this is what the POTW wants, or provide
alternative computations and/or documentation.
3. Ammonia: The HWA does not address Ammonia but does address TKNi . The
POTW's current approved MAHL for Ammonia is 56.45 lbs/day based on
Passthrough and the IUP limit for Townsends results in over allocation based on this
MAHL. The POTW must either provide a new MAHL for Ammonia that supports
the Townsends limit. or alternatively, reduce the IUP limit Perhaps the POTW could
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provide some documentation or calculations on translating the proposed TKN MAHL
into an Ammonia MARL. We have made some preliminary computations (copy
attached) based on any Ammonia/TKiN ratio developed using typical domestic levels
Ammonia and Organic Nitrogen values from Metcalf & Eddy. However, the SILT
data shows a remarkably different Ammm-,.-`K*\i ratio.
4. Phosphorus: The POTW's current approved MARL for Phosphorus is 15.98 lbs/day
based on Passthrough. The SIU's current discharge has an average of 13.1 mg/1. At
0.2 MGD, this represents 21.8 lbs/day, more than the POTW's entire MAHL. It is
understood from the IUP that the SIU will provide additional phosphorus removal
above the current treatment. However, in order for the SIU's discharge to represent
less than 5% of the current MAHL of 0.8 lbs/day at 0.2 MGD, the SIU can discharge
no more than 0.48 mg/l. The POTW must either submit an updated HWA for
Phosphorus or submit other documentation .
5. Short Term Monitoring Plan (STMP): The Division's June 30, 2000, HWA Review
letter required the POTW to respond by December 1, 2000, with an updated STMP.
A review of the Pretreatment Program files for the Town of Pittsboro by indicates a
response has not been received. Please review your files and submit the required
information.
Response to this letter is required by April 15, 2001. Please note our new mailing address and
fax number at the bottom of this page. Thank you for your continued cooperation with the
Pretreatment program. If you have any questions or comments, please contact me at (919) 733-
5083 (ext. 523) [email: [e-mail]], or Tom S. Poe (ext. 522), Supervisor of the
Pretreatment Unit.
Sincerely,
Dana Rees Folley
Pretreatment Staff
drf/Pittsboroh,,%a 003
enclosure DwQ June 30, 2000. letter
cc Central Files
DRF. Pretreatment Unit. with enclosure
Ken Schuster/Pretreatment files. Ralel!zh Regional Office
0

• List the IUP effective date of October 1, 1999, instead of (or in addition to) the IUP issuance
or signature date of December 21, 1999.
4. rUP Modification and IUP Renewal Documents: IUP renewals include a complete 1UP
submission, including:
• Copy of the letter transmitting the IUP to the SILT
• rUP, including modification history entry that uses the phrase "rUP renewal' and lists all
changes the IUP renewal made over the previous IUP or 1UP modification.
• IUP synopsis.
• SIU's application.
• POTW's latest inspection.
• Updated Allocation Table.
The effective date cannot be earlier than the date the IUP is signed. The IUP must be transmitted
to the SIU on or before the effective date. All listings of the effective and expiration dates must
be consistent throughout the IUP package.
If any item is or has been submitted to the Division under separate cover, please identify this in
the IUP submission.
IUP modifications must have the following pages:
• Copy of the letter transmitting the IUP modification to the SIU
• New rUP cover sheet with a new effective date and new signature date.
• New modification history page with an entry for that modification
• Any other pages of the IUP that are modified.
All these pages must have the same effective date, and that effective date cannot be earlier than
the date the IUP is signed. The IUP modification must be transmitted to the SIU on or before the
effective date.
5. IUP Status and Effect on Next HWA Due Date and STM? Development: As discussed in the
Division's June 30, 2000, HWA Review letter, the POTW's HWA and IUP issuance schedules
do not coincide. That letter pointed out that IVPs may be issued for a period not to exceed 5
years. The current IUP, originally issued by the Division and subsequently modified by the
POTW, became effective August 1, 1997 and therefore the POTW may extend the current IUP
to expire July 31, 2002. The HWA letter established STMT and HWA submission schedules
based on the POTW performing this extension. By October 31, 2000, please either submit an
appropriate IUP modification, or alternatively, notify the Pretreatment Unit that the IUP will not
be extended so that a new STMP and HWA schedule may be established.
Response to items 2 and 5 of this letter, if necessary, is required by October 31, 2000. Please note our new
mailing address and fax number at the bottom of this page. Thank you for your continued cooperation with
the pretreatment program. If you have any questions or comments, please contact Dana Rees Folley at (919)
733-5083 (ext. 523) [email:[e-mail]], or Tom S. Poe (ext. 522), Supervisor of the Pretreatment
Unit.
Sincerely,
(0,-, S )0-1�
Kerr T. Stevens
drf/pittsboroiup 003 A i
enclosures. marked up IUP modification history
cc Central Files
DRF, Pretreatment Unit, with enclosures
Beth Barnes, Raleigh Regional Office
NC—DENR, DWQ, PRETREATMENT UNIT Telephone [phone] Fax [phone]
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer
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Part I, SpecificlConditions
Industrial User Pretreatment Permit (1UP)
C. Permit Modification Histo :
Date Originally Issued Reason for Description of modifications
8/1/97 Permit Originally Issued w/ 40 CFR 433.17 limits
Dates Modifod
10/15/97 Permit odified: Sampling requirements changed from
compos: e to grab sampling for all pollutants due to
volume f discharge and wastewater holding tank:
Establis ed interim and final limits requirements (final
limits t e affect Dec. 1, 1997 to reduce monitoring
frequency for SIL)
4/1/98 Raised Phosphorus limit for Pipe 01. Lowered flow and
jcyanide �imits for Pipe 02. Revised the following sections
to clarify conditions: Part I, I, 5, and III, 2 reporting
requireents; Revised Part iii, 2. — flow requirements;
{I I
6/26/98 Permit giodified: Extended expiration date. Removed
limits at!Pipe 01 (permittee must still comply with SOC
requirements). Lowered flow and cyanide limits for Pipe
02. Re�ised the following sections to clarify conditions:
Part 1 G, clarification of wastestreams discharged
Part I, I, generally to add definitions
Part I, 1, 8, and 1II, 2 — reporting requirements
Part II, I, -slug spill control plan submittal,
Implementation, and update requirements
�! I Part II, 2. — flow requirements
IUP iss ed by the POTW expiration date 10`,30\99.
1U11/9a
permit by POTW, expiration date 10/30:'01

o0 F ,v A, Fq pG
Achae: F Easlev
Go,,emor
William G Ross. Jr Secretary
North Carolina Department of Environment and Natural Resources
Kerr T Stevens, Director
Division of Water Quality
March 23, 2001
MR. WALLY JENKINS
DIRECTOR OF WATER RESOURCES
TOWN OF NORTH WILKESBORO
PO BOX 759
PITTSBORO NC 27312
Subject: Pretreatment Unit Review of the POTW Program Files
Town of Pittsboro (NPDES # NC0020354)
Chatham County -
Dear. vlr. Jenkins:
A review of the Pretreatment Program files for the Town of Pittsboro by the Pretreatment Unit of
the Division of Water Quality indicates the required responses to the Division's August 17, 2000,
Industrial User Pretreatment Permit (IUP) Review letter (copy attached) has not been received.
Please review your files and submit the required information.
Response to this letter is required by April 15, 2001. Please note our new mailing address and
fax number at the bottom of this page. Thank you for your continued cooperation with the
pretreatment program. If you have any questions or comments, please contact me at (919) 733-
5083 (ext. 523) [email- [e-mail]], or Tom S. Poe (ext. 522), Supervisor of the
Pretreatment Unit.
Sincerely,
Dana Rees Folley
Pretreatment Staff
drf/putsborotrucs 002 iup response
enclosure DWQ August 17. 2000. letter
cc Central Files
DRF. Pretreatment Unit. with enclosure
Ken Schuster/Pretreatment files. Raleigh Regional Office
Vu
NC—%CD\VQ, PRETREATMENT um,r 1'elephone: 919-733-3083 Far: 919-713-29.11 S*A
1617 %1 W. 1,110 1CF CFN 11• R. It \1 } 1(;11. Nl' 276119-1617 \n F tlual OpportunttN ,\flit mati\e Action b niplmer NCDENR
1\ehsttt littp://h2o.eilr.state.iic.tis/1'retreat/inciex.htnil 30 c? rec}clecUll►c'c post -comtinier paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
MR. WALLY JENKINS
DIRECTOR OF WATER RESOURCES
TOWN OF NORTH WILKESBORO
PO BOX 759
PITTSBORO NC 27312
4 ffl�!W
•
lrAA
Am�� - �
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 17, 2000
Subject: Pretreatment Unit Review of Industrial User Pretreatment Permit (IUP)
Town of Pittsboro (NPDES # NC0020354)
Chatham County
Dear Mr. Jenkins:
The Pretreatment Unit of the Division of Water Quality has reviewed the Industrial User Pretreatment permit
(IUP) issued by the Town of Pittsboro for the following Significant Industrial User (SIU). This IUP was
received by the Division on July 13, 2000.
UP # SIU Name
001 H drotube South, Inc.
The review indicates that, with the observations outlined below, the IUP is adequate and the minimum
requirements of 15A NCAC 2H .0905 and .0916 and 40 CFR 403.8(f)(1)(iii) is met.
Concerns noted that do not require re -submission of the IUP at this time are as follows. However, they must
be corrected in or with the next IUP modification or renewal.
Retroactive rUP Effective Date: The IUP was signed December 21, 1999, but had an IUP
effective date retroactive back to October 1, 1999. Issuing retroactive permits is explicitly
prohibited by the state pretreatment rules 15A NCAC 2H .0916(c)(7)(C), effective November 1,
1994. Please ensure this does not occur in the future.
2. ILJP Status: The IUP modification history entry for this IUP refers to it as a "reissue" of the NP.
IUP reissues or renewals involve the SIU completing a new application. It is assumed that in fact
no new application was submitted by the SIU and that this IUP is really an IUP modification to
extend the expiration date. If this is not the case, please forward a copy of the items listed below
for IUP renewals to the Pretreatment Unit by October 31, 2000.
IUP Modification History: The next time the IUP is modified or renewed, please correct the IUP
modification history for this 1UP to the following:
• List the IUP as an IUP modification rather that an IUP "reissue."
NC—DENR, DWQ, PRETREATMENT UNIT Telephone [phone] Fax [phone]
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer
Website: http://h2o.enr.state.nc.us[Pretreat/index.htmi 50% recycled/10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr.. Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
June 30, 2000
MR. WALLY JENKINS
DIRECTOR OF WATER RESOURCES
TOWN OF NORTH WILKESBORO
PO BOX 759
PITTSBORO NC 27312
1 � •
NCIDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Pretreatment Unit Review of Headworks Analysis, (HWA Approved)
Pretreatment Unit Review of Industrial User Pretreatment Permit (IUP) Files
Town of Pittsboro (NPDES # NC0020354)
Chatham County
Dear Mr. Jenkins:
The Pretreatment Unit of the Division of Water Quality has reviewed the Headworks Analysis
(HWA) for the Town of North Wilkesboro. This HWA was prepared by me based on information
received by the Division during my October 14, 1998, meeting with John Poteat of the POTW, with
additional information received between that meeting and June 27, 2000.
The Division concurs with the HWA calculations for all pollutants of concern. These approved
Maximum Allowable Headworks Loadings (MARL), Maximum Allowable Industrial Loadings
(MAIL.), and the basis for these values are found on the last page of the enclosed HWA spreadsheet.
The results of the HWA are also listed in the bottom section of the enclosed Allocation Table.
The following observations were noted during the review of the HWA:
1. HWA Documents: Attached please find all applicable spreadsheets and notes and
calculations related to the HWA in hardcopy and computer spreadsheet form. I apologize
for the long delay in sending this approval letter. Because so much time has passed, and
the POTW staff has changed, I suggest you use these documents as your approved HWA,
AT, and supporting information. There were a number of different versions of the HWA
and other spreadsheets created and/or printed between my initial October 14, 1998,
meeting with John Poteat of the POTW, and his final November 12, 1998, email
submission. Also, his final November 12 email submission still had the incorrect
removal rate, MARL, and MAIL for mercury, and the AT did not have the current IUP
limits. If you wish to keep your earlier computer and hardcopy versions, feel free, but
please mark them as "draft" so as not to get them confused with these documents. Please
review these HWA documents and feel free to contact me for clarification on any issues.
NC—DEN'R. DWQ, PRETREATMENT UNIT Telephone [phone] Fax [phone]
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer
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Next HWA i a T evelo ment and IUP Status: The POTW is a
NI-dified Pretreatment Program and as such is required to implement a Short Term
Monitoring Progr9UW4ifjh� scally rgiSeptemberata collection
1998 Typically your next STMP
e HWA
was based on data from July W97 through
implementation would be July 2002 to Apn12003, with your HWA due in July 2003.
Ideally, the HWA and NP renewal schedules
the POeTW's theHWA
and due
lLTpaissuance
te is 3-6
months before the NP expires. However,
schedules do not coincide.
Ii -Ps may be issued for a period not to exceed 5 years. The current NP, originally issued
by the Division and subsequently modified by the POTW, became effective August 1,
1997, Therefore the POTW may extend the current IUP to expire July 31, 2002. (See
item 3 below for more NP requirements.) If this is done, to allow the HWA and NP
schedules to be concurrent, the following schedule shall apply. If this schedule is not
acceptable, please contact me to discuss other possibilities.
• by December 1, 2000: POTW must review current Short Term Monitoring Plan
(STNIP) and update as necessary, and submit to DWQ for approval.
• 'March 2001 through December, 2001: STMP data collection (assuming 4 samples
collected one sample per quarter -March. June,
October, and December).
• by April 1, 2002: Perform and submit a site-specific HWA.
3. ILP Submittals: Our records show a POTW issued NP modification in September 1998
that became effective on October 1, 1998 and expired on October 31, 1999. It is
understood that the POTW has issued another NP modification to extend the IUP to
approximately October 30, 2001,, however we do not have a copy. The State General
Pretreatment Regulations 15A NCAC 2H.0917(a) unce.guires POTWs to Please forward a copyofall IUP
and IUP modifications to the Division upon
modifications issued after the September 30, 1998 NP modification to the Pretreatment
Unit by July 15, 2000.
Once again. I apologize for the long delay in sending this HWA approval letter. Response to item
2 of this letter (STMP and HWA) is required by December 1, 2000, and April 1, 2002. Response
to item 3 of this letter (NPs) is required by July 15,
2000. Please note our new mailing address and
fax number at the bottom of this page. Thank you for your continued cooperation with the
pretreatment program. If you have any questions or comments, please contact me at [phone]
(ext. 523) [email: [e-mail]], or Tom S. Poe (ext. 522), Supervisor of the Pretreatment
Unit.
Sincerely,
Dana Rees Folley, Pretreatment Staff
drf/pittsborohwa 002
enclosures HNVA and AT spreadsheets, and supporting documentation
cc Central Files
DRF Pretreatment Unit, with enclosures
Beth Bames, Raleigh Regional Office
NC—DEAR, DWQ, PRETREATMEN lJ-1IT
1617 MAIL SERVICE CENTER. RALEIGH. NC 27699-1617
N\ ebsite: http://h2o.enrstate.nc.us/Pretreat/index.html
Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Emplover
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