NC0020354_Compliance Evaluation Inspection_20021028

State of North Carolina
Department of Environment
. and Natural Resources
Raleigh Regional Office
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Division of Water Quality
October 28, 2002
Mr. Hugh Montgomery, Town Manager
Town of Pittsboro
P.O. Box 759
Pittsboro, NC 27312
L&T IM,
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Pretreatment Compliance Inspection
Pittsboro WWTP_,
NPDES Permit No.N00030254'. L2 ® �
Chatham County
Dear Mr. Montgomery:
On October 23, 2002, Mr. Myrl Nisely of the Raleigh Regional Office met with Perry Dunn to conduct
an annual Pretreatment Compliance Inspectio of the WWTP facility Mr. Dunn's assistance was
greatly appreciated. Findings during the inspection were as follows:
There is one Significant Industrial User, HydroTube, a Categorical Industrial User. The SIU was
not in SNC during either of the last two Semi -Annual Periods for either a reporting or a limits
violation.
2. During the pretreatment inspection file review of HydroTube (Permit No.0001), the files needed
for review were available for inspection, contained all the required elements and were in excellent
condition.
3. Flow reporting by Hydrotube continues to be done as a weekly average instead of daily
documentation. This violates the HydroTube permit, which calls for reporting daily values. A
letter of NOV is to be issued to them (again) to correct this error.
4. The POTW is awaiting a letter of approval from the Division for renewal of this SILT permit.
5. There has been no further sampling done for the STMP since the last PCI. The plan was being
followed at that time, including proper detection limits.

Pittsboro PCI, Oct. 23, 2002 P. 2
6. A Total Toxic Organics Management Plan had been submitted to the POTW since the last
inspection, and monthly certifications are in the file.
7. While a new Industrial Waste Survey is to be submitted to the Division in 2003, good
communication from city government offices alerts the POTW to any new activity as it occurs.
8. A new Headworks Analysis (HWA) was submitted ahead of the August 1 deadline
If there are any questions or comments, please contact me at [phone].
Sincerely,
�y 0-
Myrl A. Nisely
Environmental Specialist II
Enclosure: Inspection Report
cc: Perry Dunn, Pittsboro WWTP
Tom Poe, Central Office Pretreatment Unit
Central Files
1628 Mail Service Center, Raleigh, NC 27699-1628 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

1rViCln %-a ujuirlEi lJlvxaxuiN Vl' vv A1L,1m %zu x
PRETREATMENT COMPLIANCE'INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)j
t 1. Control Authority (POTW) Name: Town of Pittsboro
2. Control Authority Representative(s): Perry Dunn
3. Title(s): Public Works Director / ORC
4. Last Inspection Date: 6/27/02 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 Fac. Type
N I N I C 10 10 12 1 0 1 3 1 5 14 1 1 10 123 1 02 1 LPJ LS
(DTIA) (TYPI) (INS
7. Current Number Of Significant Industrial Users (SIUs)? 1
I I I
P) (FACC
SNS
8. Current Number Of Categorical Industrial Users (ClUs)?
1
CNS
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
L0
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
�00
MSNC
15. Number of SILTS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SLAPS
16. Number of SILTS 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? LJ Yes ® No
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 ❑ Yes ® No
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 during either of the Last 2 Semi- SNC for Limits: None
Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: None
2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: None
(May refer to PAR if Excessive SIUs in SNC)
20. Which Industries are on Compliance Schedules or Orders? For all S1Us on an
Order, Has a Signed Copy of the Order been sent to the Division? None
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which ❑ Yes ® No
Ones?
Filename: PittsboroPCI10_23_02 Page 1

- PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files and complete the following:
Program Element
Date of Last Approval
Date Next Due, If Applicable,
Headworks Analysis (HWA)
submitted 7/26/02
Industrial Waste Survey (IWS)
10/13/98
10/1/2003
Sewer Use Ordinance (SUO)
11/25/97
Enforcement Response Plan (ERP)
10/13/98
/
Long Term Monitoring Plan (LTMP)
3/4/02
LTMP FILE REVIEW:
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? [E Yes E] 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 n No
25. Is the LTMP Data Maintained in a Table or Equivalent? ® Yes ❑ No Is the Table Adequate? ® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEWO IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTioN1
i
26. User Name
1. HydroTube 2.
3.
27. IUP Number
1 0001
28. Does File Contain Current Permit?
I ® Yes [:] No
Yes No Yes No
29. Permit Expiration Date
1 7 /31/07---]l
/
30. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
1 433
31. Does File Contain Permit Application Completed:Withiri One Year Prior
® Yes No
Yes ❑ NoYes ❑ No
. to Permit Issue Date?
32. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
E] Yes E] No EEE] Yes 1:1 No
33. a. Does the File Contain a Slug Control Plan?
a. ®Yes ❑No
a. ❑Yes []No a. ❑Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. QYes ❑No 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 Ma gement-P1
35. a. Does File Contain Original Permit Review Letter from the Division?
a. ❑Yes ENo
a. ❑Yes ❑No a. ❑Yes ❑No
b. 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 E] No Ej Yes ❑ No
its Sampling -as Required by IUP?
37. Does File Contain POTW Sampling Chain -Of -Custodies?
® Yes No
E] Yes [j No El Yes E] No
38. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A ❑Yes❑No❑N/A
Sampling as Required by IUP?
39. Does Sampling Indicate Flow or Production?
❑YesSNo❑N/A
❑Yes❑No❑N/A [3Yes❑No❑N/A
40. During the Most Recent Semi -Annual Period, Did the POTW Identify
E]Yes 0 No
Yes ❑ No El Yes E] No
All Non -Compliance from Both POTW and SIU Sampling?
N/A
41. a. Was the POTW Notified by SILT (Within 24 Hours) of All Self-
a.❑Yes❑NoSN/A
a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample Within 30 Days?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
42. Was the SIU Promptly Notified of Any Violations (Per ERP)?
❑Yes❑NoSN/A
❑Yes❑No❑N/A ❑Yes❑No❑N/A
43. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
❑ Yes ❑ No E] Yes ❑ No
44. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoSN/A
❑Yes❑No❑N/A ❑Yes❑No❑N/A
as Specified in the POTWs ERP?
45. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoSN/A
pYes❑No❑N/A ❑Yes❑No❑N/A
46. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoSN/A
❑Yes❑No❑N/A ❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
47. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/Aa.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
Yes No Yes No
48. Did the POTW Representative Have Difficulty Cb, tainingMry of This
Yes ® No
Requested Information For You?
Filename: PittsboroPCI10_23_02 Page 2
s

Good organization, Mr. Dunn was even more familiar with the files.
35. No letter of approval has yet been received from the Division.
PCI SUMMARY AND COMMENTS:
PCI Continents:
Requirements: Issue another NOV to Hydrotube for failure to supply daily flow reports as required by their permit. Reminder: on days
when either the SIU or the POTW samples, note the flow in order to have that information with the laboratory results.
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Mvrl Nisely DATE: 10/23/02
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
--- -- u is I u
(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: PittsboroPCII0_23_02 Page 3

i'Yov