NC0020354_NOV of Part III Permit_20020304

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Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
March 4, 2002
CERTIFIED MAIL 7000 1530 0002 2099 0053
RETURN RECEIPT REQUESTED
MR. HUGH MONTGOMERY, TOWN MANAGER
TOWN OF PITTSBORO
PO BOX 759
PITTSBORO NC 27312
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
Subject: NOTICE OF VIOLATION —
Failure to Submit A Modified Program Pretreatment Annual Report (PAR)
Failure to Submit and Implement a Short Term Monitoring Plan (STMP)
Failure to Issue Adequate Industrial User Pretreatment Permits (IUPs)
Failure to Submit IVPs to the Division Upon Issuance
Failure to Respond Adequately to a Division Notice of Deficiency (NOD)
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 Town of
Pittsboro's Pretreatment Program. The review indicates that the Town of Pittsboro is in
violation of its Division approved Pretreatment Program as required by Part III of the
Town's NPDES Permit and 15A NCAC 021-1.0900 for the following:
1. Failure to submit a Modified Pretreatment Program Pretreatment Annual Report (PAR) by
March 1, 2002, as required by Part III, B, 10., of your NPDES permit and the Division's
December 19, 2001, letter.
2. Failure to submit a Short Term Monitoring Plan (STMP) to the Division for review and
approval and then implement the STMP in accordance with Part III, B, 3., of your NPDES
permit. The STMP was initially due December 1, 2000, and the Division's June 14, 2001,
Notice of Deficiency (NOD) established a due date of July 15, 2001. No STMP has been
received to date.
3. Failure to issue adequate Industrial User Pretreatment Permit (IUP) issued to Hydro Tube
South as required by Part III, B, 5, of the Town's NPDES permit. The IUP was initially due
October 30, 2000, and the Division's June 14, 2001, Notice of Deficiency (NOD) established
a due date of July 15, 2001. An IUP was received June 27, 2001, but it did not address the
Division's concerns. Additionally, the Town has Issued an IUP that extended the expiration
date beyond the 5 year limit allowed under 15A NCAC 02H .0916(c)(6)(D).
4. Failure to submit a copy of the Industrial User Pretreatment Permit (IUP) issued to Hydro
Tube South in October of 2001 to the Division as required by 15A 2H NCAC .0917.
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NC—DENR, DWQ, PRETREATMENT UNIT "Telephone: [phone] Fax: [phone] NCDENR
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer
Website: http://h2o.enr.state.nc.us/Pretreat/index.html -50% recycled/10% post -consumer paper

5. Failure to respond properly to the Division's June 14, 2001, Notice of Deficiency (NOD). In
addition to failure to meet the above discussed July 15, 2001, due dates for the IUP and
STMP, the Town failed to provide a response outlining causes of the violations and actions to
resolve the violations.
You are directed to respond in writing no later than April 1, 2002, 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 these violations, and actions
the POTW has and/or will take to ensure that future violations will not occur.
You are further directed to submit the documents as outlined in the Attachment by April 1, 2002,
or as directed.
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 $25,000 per day per violation.
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: dana.folley @ncmail.net], or Myrl Nisely
of the Division's Raleigh Regional Office at (919)-571-4700, ext. 246.
Sincerely,
Tom S. Poe
Pretreatment Unit Supervisor
drf/pittsboromisc..004.nov. iup. stmp
enclosures: June 14, 2001, Notice of Deficiency
Division approved Short Term Monitoring Plan (STMP)
Marked up Hydro Tube South Permit History
Disc with STMP and HWA, AT, and data summary worksheets — MR JENKINS ONLY
cc with enclosures:
Mr Wally Jenkins, Director of Water Resources, Town of Pittsboro
DRF, Pretreatment Unit
cc without enclosures:
;'�ea�tral-F�lzs
Bill Reid, Point Source Branch Supervisor
Myrl Nisely, Raleigh Regional Office
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ATTACHMENT:
Modified Pretreatment Program Pretreatment Annual Report (PAR):
a) By April 1, 2002, submit to the Pretreatment Unit two copies of a Modified Program
PAR. In addition to all items required by the Division's December 19, 2001, letter, also
include either compliance judgement worksheets or data summaries with all violations
marked.
Short Term Monitoring Plan (STMP):
a) Begin immediately to implement the attached STMP (collect first round of samples in
March 2002). Fax copies of all data to the Pretreatment Unit within 3 days of receipt of
lab reports.
Headworks Analysis (HWA):
a) By August 1, 2002, submit to the Pretreatment Unit an updated HWA using the STMT
data.
Hydro Tube South IUP:
a) By April 1, 2002, submit to the Pretreatment Unit a copy of the IUP issued to Hydro
Tube South in October of 2001. Include a copy of the letter transmitting the IUP to the
SIU.
b) By April 1, 2002, issue an IUP modification to Hydro Tube South that changes the
expiration date to July 31, 2002, and submit a copy to the Pretreatment Unit.
i) Ensure the IUP has the following:
(1) an effective date no earlier than the day the IUP is signed. Include this same
effective date throughout the IUP as appropriate, especially in the permit history
and on the limits page.
(2) include a complete permit history with an entry for all IUP modifications. Please
see attached marked up page for suggested wording.
c) By April 1, 2002, submit to the Pretreatment Unit a copy of a letter sent to Hydro Tube
South establishing a May 1, 2002, due date for submittal of a new completed application.
d) By August 1, 2002, issue an IUP renewal to Hydro Tube South, and submit a copy to the
Pretreatment Unit.
e) You are•reminded that IUP modifications include the following:
i) Copy of the letter transmitting the IUP modification to the SIU.
ii) New IUP cover page with a new effective date and new signature date.
iii) New permit history page with an entry for that modification that uses the phrase "IUP
modification" and lists all changes the IUP renewal made over the previous IUP or
IUP modification.
iv) Any other pages of the IUP that are modified.
v) Updated Allocation Table.
vi) 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, with a copy to the Division.
f) You are reminded that IUP renewals include the following:
i) Copy of the letter transmitting the IUP to the SIU.
IUP, including permit history entry that uses the phrase "IUP renewal" and lists all
changes the IUP renewal made over the previous IUP or IUP modification.
iii) IUP synopsis.
iv) SIU's application.
v) POTW's latest inspection.
vi) Updated Allocation Table.

vii)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, with a copy to the Division.
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.
MAA - 4 2002 > JLI
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