NC0020354_Compliance Evaluation Inspection_20020930

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Michael F Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 30, 2002
Mr. Hugh Montgomery, Town Manager
Town of Pittsboro
P.O. Box 759
Pittsboro, NC 27312
Subject: Pretreatment Compliance Inspection
Pittsboro WWTP
NPDES Permit No. NCO030254
Chatham County
Dear Mr. Montgomery:
Alan W. Klimek, P.E , Director
Division of Water Quality
On June 27, 2002, Ms. Dana Folley of the Central Office and Mr. Myrl Nisely of the Raleigh
Regional Office conducted an annual Pretreatment Compliance Inspection of the WWTP facility for
the fiscal year 2001-2002. The assistance given by John Poteat and Perry Dunn was greatly
appreciated. Findings during the inspection were as follows:
1. All due dates from the division's March 4, 2002, Notice of Violation were met, most well ahead
of time, and all violations have been resolved. We commend the Town and the late Wally
Jenkins, ORC, for his prompt resolution of the majority of violation resolution work done in
March 2002. Additionally, we commend Mr. Poteat and Mr. Dunn for resolving the final items,
despite the loss of Mr. Jenkins.
2. There is one Significant Industrial User, HydroTube, a Categorical Industrial User. Townsends,
Inc. is no longer a factor in the pretreatment program. The SIU was not in SNC during either of
the last two Semi -Annual Periods for either a reporting or a limits violation.
3. During the pretreatment inspection file review of HydroTube (Permit No.0001), the files needed
for review were available fortuspection, contained most required elements (see comments
below for minor deficiencies) and were in excellent condition. Mr. Poteat and Mr. Dunn had
made an outstanding effort to organize and become familiar with the files in a very short time,
especially under difficult staffing stresses due to the passing of the ORC Wally Jenkins.
4. During the PCI it was noted that HydroTube was only reporting flow as a weekly average. This
violates the HydroTube permit, which calls for reporting daily values. The town had not
identified this SIU violation, and so had not issued the required NOV to the SIU. An NOV for
this was issued by the Town the day after the PCI. Also, the Town was not monitoring flow
each time it sampled Hydro Tube as required by the permit. This must be corrected.
5. A Total Toxic Organics Management Plan (TOMP) could not be located, even after a phone call
to the SIU. As required by 40 CFR 433, Metal Finishing Categorical regulations, the SIU must
develop this TOMP and submit it to the Town for review in order to continue to be allowed to
NC—DENR, DWQ, PRETREATMENT UNIT Telephone: [phone] Fax: [phone] ��A
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer NCDENR
Website: http://h2o.enr.state.nc.us/Pretreat/index.htnil 50% recycled/10% post -consumer paper

file TTO certifications in lieu of TTO sampling. It is suggested that minor augmentation of the
existing Slug Spill Plan to specifically list any toxic organics describing their use and
containment procedures will be the simplest way to accomplish this TOMP.
6. A permit renewal had been issued two weeks prior to the PCI, but had not yet been submitted to
the Division. A copy was received during the PCI. The need for a change or two was identified
after a cursory scan and formal review comments will be provided by the Division under
separate cover.
7. A review of ST IP data indicated compliance with all requirements stipulated in the STMP,
including required Detection Levels.
8. The new updated Headworks Analysis (HWA) due August 1, 2002, was discussed, and a disc
with helpful computer templates was provided. Despite the very short schedule for completion
of this very complex and critical Pretreatment Program element and almost no prior training,
this date was met by Mr. Dunn. Any review comments from the Division will be provided
under separate cover.
9. A due date of October 1, 2003, was established for an updated Industrial Waste Survey (IWS).
Please review Chapter 3 of the Comprehensive Guidance for North Carolina Pretreatment
Programs for guidance on conducting this IWS.
If there are any questions or comments, please contact Dana Folley at 733-5083, ext. 523 or Myrl
Nisely at [phone].
Sincerely,
I w -J
�;
Dana Folley
Pretreatment Staff
Enclosure: Inspection Report. —
cc: Perry Dunn, Pittsboro WWTP
�Centi"a1 Files.i
Myrl A. Nisely
Environmental Specialist H

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Town of Pittsboro
2. Control Authority Representative(s): John Poteat / Perry Dunn
3. Title(s): Public Works Director / ORC
4. Last Inspection Date: 5/18/00 Inspection Type (Circle One): ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ® Yes ❑ No ❑ N/A
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ❑ N/A
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector
I N I I N I C 1 0 1 0 1 2 1 0 1 3 1 5 1 4 1 6 1 27 1 02 I L2J LSJ
Fac. Type
LLJ
(DTIA) (TYPI) (INSP)
7. Current Number Of Significant Industrial Users (SIUs)? 1
(FACC)
SIDS
8. Current Number Of Categorical Industrial Users (CIUs)?
1
CIUS
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 Year?
0
11. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
0
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any POTW Permit 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, Btockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC during either of the Last 2 Semi- SNC fo
Annual Periods? Have any Industries in SNC (During Either of the Last SNC fo
2 Semi -Annual Periods) Not Been Published for Public Notice? Not Put
(May refer to PAR if Excessive SIUs in SNC)
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?
Filename pittsboronvsc pci form
Revised 6/30/98
® Yes ❑ No
wkly BOD May 01. suspected (but
could not prove( was septage
hauler bringing in process
wastewater from 3M. sent letter to
hauler to deny further discharges.
® Yes ElNo
Septic dumping by 3M, terminated
permission to haul
-Limits: None
Reporting: None
dished: None
None
❑ Yes ® No
Page I

I
PRETREATMENT PROGRAM FT.F.MF.NT.c RFVTFW_ DI.— .•n.,:e. DnTlIT Al .._.1 -.- .t_ r_„
Program Element
Date of Last Approval
Date Next Due, If Applicable
Headworks Analysis (HWA)
6/30/00, comment ltr 6/26/02
8/1/02
Industrial Waste Survey (IWS)
10/13/98
10/1/03
Sewer Use Ordinance (SUO)
11/25/97, provided at PCI
❑ Yes ❑ No
Enforcement Response Plan (ERP)
10/13/98
Long Term Monitoring Plan (LTMP)
3/4/02
433
Ll-1Vlrr111EKhVIEW:
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes ❑ No
23. Should any Pollutants of Concern be Eliminated from or Added to the LTMP? ❑ Yes ® No
If yes, which ones? Eliminated: Added:
24. Are Correct Detection Levels being used for all LTMP Monitoring? ® Yes ❑ No
25. Is the LTMP Data Maintained in a Table or Equivalent? ❑ Yes ® No Is the Table Adequate? ❑ Yes ❑ No
INDUSTRIAL USER PF.RMTT (TTTP)PTT.F. Rii.VTF.W/-A TTTD T.M D DDVTA',zrc nD 1 = >✓ nnirrnir
26. User Name
1. HydroTube
2.
3.
27. IUP Number
0001
28. Does File Contain Current Permit?
® Yes ❑ No7j
❑ Yes ❑ No
❑ Yes ❑ No
29. Permit Expiration Date
7/31/07-71
30. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
31. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
11
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
1
32. Does File Contain an Inspection Completed Within Last Calendar Year?
1 ® Yes ❑ No
1 ❑ Yes ❑ NoI
❑ Yes ❑ No
33. a. Does the File Contain a Slug Control Plan?
a. ®Yes ❑No
a. ❑Yes ❑No
a. []Yes []No
If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
I b. []Yes []No
34. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
11
35. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ❑Yes ❑No
a. []Yes []No
All Issues Resolved?
b ❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
36. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP?
37. Does File Contain POTW Sampling Chain -Of -Custodies?
I ® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
38. During the Most Recent Semi -Annual Period, Did the SN Complete its
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP?
11
39. Does Sampling Indicate Flow or Production? _
❑Yes®No❑N/A
❑Yes❑No❑N/AJ
❑Yes❑No❑N/A
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ Yes ®.No
❑ Yes ❑ No
❑Yes ❑ No
All Non -Compliance from Both POTW and SIU Sampling?
41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑NoON/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resam le Within 30 Days?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
42. Was the SILT Promptly Notified of Any Violations (Per ERP)?
❑Yes®No❑N/A
❑Yes❑No❑N/A
I ❑Yes❑No❑N/A
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑Yes ® No 11
❑ Yes ❑ No 11
❑ Yes ❑ No
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑YespNo❑N/A
as Specified in the POTWs ERP?
11
45. Does the File Contain Penalty Assessment Notices?
❑YespNoON/A
❑Yes❑No❑N/A 11
❑Yes❑No❑N/A
46. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑YespNo❑N/A
❑Yes❑No❑N/A
47. a. Does the File Contain Any CurrentiFKf— rcement`�Orders?
b. Is SIU in Compliance with Order? -
a.❑Yes❑No®N/A
b.❑YespNo®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b ❑Yes❑No❑N/A
48. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
El Yes ❑ NolFr�No
Requested Information For You? Bltq `T — � 2Qd-_)
Filename putsbororrusc pcilorm Page 2
Revised: 6/30/98

r 111n nrl Vin YY l.V1Yl1 lie1l11J:
questions 38 - 44 were "NO" because SIU did not perform daily flow monitoring as required by permit AND POTW failed to identifie this
SIU violation. POTW resolved this failure the day after the PCI with an appropriate NOV to the SIU.
Good organization, but it might help to separate program items such as letters of approval from the SIU files for easier retrieval
PCI SUMMARY AND COMMENTS:
PCI Comments: A good effort has been made to organize the files and continue the pretreatment program after the passing of ORC Wally
Jenkins.
A renewed permit was issued two weeks ago to HydroTube. Per SOP, Dana will review it -- there were a couple of problems noted.
Requirements: Issue a NOV to HydroTube for failure to supply daily flow reports as required by their permit. On days when either the
SIU or the POTW samples, the flow is to be noted in order to have the information with the laboratory results. NOTE: On July 5, 2002,
DWQ received the required NOV the POTW had issued the day after the PCI.
Recommendations: Begin inputing STMT data into the Removal Rate file provided during the inspection.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Dana Folley and Myrl Nisely DATE: 6/27/02
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
IJ I 1 LTJ LS -1 Ll -I
(DTIA) (TYPI) (INSP) FACC)
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 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:
Filename: pittsboromisc pci form Page 3
Revised 6/30/98

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