NC0020354_Audit Inspection_20040914

Mr. David Hughes
Town Manager
Town of Pittsboro
P O Box 759
Pittsboro, NC 27312
Dear Mr. Hughes:
Michael F. Easley, Governor,=_-.
William G. Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources I�
Alan W. Klimek, P.E. Director
Colleen H. Sullins, Deputy Director
Division of Water Quality
September 14, 2004
Subject: Pretreatment Audit Inspection
Pittsboro WWTP
NPDES Permit No. NCO020354
Chatham County
On September 8, 2004 Jerry Rimmer of the Raleigh Regional Office and Deborah Gore of DWQ
Central Office conducted an audit of Pittsboro WWTP pretreatment program. A copy of the audit
inspection form is attached. The assistance Perry Dunn provided during this inspection was greatly
appreciated. Findings were as follows:
1. The program currently has 1 SIU; SIU is listed as 433 categorical. SIU was not in Significant
Non Compliance (SNC) during the past year.
2. A file review of Hydro Tube, Inc. was conducted. The files needed for review were readily
available, up to date and well organized. Analytical data is reviewed as soon as it is
received. Your pretreatment program has performed appropriate tracking. Annual site
inspections of the facility have been performed.
3. A misunderstanding of analytical requirements was discovered. The lUP states that SILT
will sample 1/6 months and POTW will sample 1/6 months. Actual practice is that SIU
samples one semi-annual term and the POTW samples the other semiannual period.
Regulations require that the POTW sample 1/6 months (twice per year), but does not require
SILT sampling. Mr. Dunn stated that POTW will do all future sampling and will modify the
IUP. The IUP for Hydro Tube, Inc. should be revised immediately to correct the
sampling requirements and be submitted to Deborah Gore for approval by October 31,
2004. °
4. During the audit questions regarding the Total Toxic Organic (TTO) and trichloroethylene
sampling requirements were discussed. The SIU has submitted sufficient data to
demonstrate their compliance with the TTO limit. You may allow the SIU to discontinue
the sampling and just submit the semi-annual certification statement. Trichloroethylene is
Raleigh Regional Office 1628 Mad Service Center One
Water Quality Section Raleigh, NC 27699-1628 NorthCarolina
AMtur74
phone [phone] Customer Service
facsimile [phone] 1-877-623-6748

Page 2
Pittsboro PT Audit Report
September 14, 2004
part of the TTO analysis, but was singled out due to concerns with this compound when
the SIU permit was initially issued. Review this data in particular and make sure the SN is
not discharging at over 5% of the Maximum Allowable Headworks Loading (MAHL). Five
percent of the MAHL for trichloroethylene is 0.1156 pounds per day. If you need assistance
in determining if the trichloroethylene discharge is at less than 5% of the MAHL please
contact Deborah Gore of the PERCS Unit at 919-733-5083, ext. 593.
5. Records of DWQ Pretreatment staff approval of all pretreatment program components are
maintained appropriately.
6. The Audit included a facility inspection at Hydro Tube, Inc. Mr. Dunn demonstrated good
knowledge of the facility and excellent rapport with the site contact.
7. Due to regulatory changes in the amount of civil penalties that may be assessed, the Town's
Sewer Use Ordinance and Enforcement Response Plan will need to be updated. At this time
the Pretreatment, Emergency Response and Collection Systems (PERCS) Unit is working on
guidance to aid in making these required updates. When the guidance is completed a copy
will be sent to you and a due date of at least eight months later will be set.
The pretreatment program is well organized, well documented and is being managed in a timely
manner. We appreciate the outstanding commitment given to Pittsboro's pretreatment program. If
you have any questions or comments, please call me at [phone].
Sincerely,
Jerry F. Rimmer
Environmental Specialist
/Enclosure: 2004 Pittsboro Audit Inspection Form
cc: Perry Dunn, Pretreatment Coordinator, Pittsboro WWTP
Chatham County Health Department
Deborah Gore, Pretreatment Central Office
Central Files
b

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Pittsboro
2. Control Authority Representative(s): Perry Dunn
3. Title(s): Senior Plant Operator/Pretreatment Coordinator
.4. Address of POTW: Mailing: PO Box 759
City Pittsboro, NC Zip Code: 27312
Phone Number- [phone] Fax Number: [phone]
5. Audit Date: 09/08/2004
6. Last Inspection Date: 09/09/2003 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? Yes
If No, Explain. Filing procedures adjusted as suggested in last PCI.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? No
If Yes, Explain. One Nickel violation in November 2003-POTW issued NOV-2004-LV-0370- Limit is 25ug/l results
were 27ug/1-Unusual analytical number All other results were non detect.
9. Is POTW under an Order That Includes Pretreatment Conditions? No
Order Type and Number: _
Parameters Covered Under
PCS (WENDB)Coding
Trans. Code
I_N_I
Main Program Permit Number
NIC101010101010101
Are Milestone Dates Being Met? Yes / No
MM/DD/YY Inspec.Type Inspector
09/08/2004 1-9-1 1_S 1
(DTIA) (TYPI) (INSP)
10. Current Number of Significant Industrial Users (SNS)?
.... ......... ......... ....... .
11. Current Number of Categorical Industrial Users (CNS)? (433)
12: Number of SIUs Not Inspected by POTW in the Last Calendar Year?
.... ............ .... ........ . ........
13. Number of SIUs Not Sampled by POTW in the Last Calendar Year?
.. ........ ... .............. .......
14. Enter the Higher. Number. of 12 or 13
15. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Senn -Annual Periods (Total Number of SIUs in SNC)
16. Number of SIUs with No IUP or with an Expired IUP
........... ... ............. ............
17. Number of SIUs in SNC for Reporting During Either of the Last 2 Semi -Annual Periods
.... ........ ....... .
18. Number of SIUs in SNC for Limits Violations During Either of the Last 2 Seirn-Annual Periods
... .................. ......... .. I.... .........
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2
Semi -Annual Periods
......... .......... . ............ ................. . ............. .... ......... ....... . ...... .....
20. Number of SIUs in SNC for Self-Momtoring Requirements that were Not Inspected or Sampled
Filename. Pittsboro Audit Report'04revised
Page 1
Revised: 06/30/98
1
1
0
0
0
0
0
0
0
0
0
Fac Type
U-1
(FACC)
SIDS
CIUS
NOIN
PSNC
MSNC
W1 I�►1

PRETREATMENT PROGRAM FT,F,MF,NTS RF.VTFW- Please review POTW filar —1 — 1AtP +bA
Program Element
Date of Last Approval
Date Next Due, If Applicable
**Headworks Analysis (HWA)
12/12/2003
8/1/2008
Industrial Waste Survey (IWS)
9/26/2003
9/30/2008
Sewer Use Ordinance (SUO)
11/25/1997
Enforcement Response Plan (ERP)
10/13/1998
Send guidance for $25,000 update &
set date 8 months out
Long Term Monitoring Plan (LTMP)
9/5/1997
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? No
If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Inteijunsdictional Agreements (IJAs) or other Contracts?
23. If yes to #21, Have you had any trouble working with these towns or districts?
If yes, Explain.
24. Date of Last SUO Adoption by Local Council? 10/27/1997
25. Have you had any problems interpreting or enforcing any part of the SUO? No
If yes, Explain.
Enforcement (Enforcement Response Plan -ERP)
26. Did you send a copy of the ERP to your industries? Yes
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudications, improper enforcement, etc.)?
If yes, Explain. No
28. List Industries under a Schedule or Order and Type of Schedule or Order: NA
Filename: Pittsboro Audit Report'04revised
Page 2
Revised: 06/30/98

Resources
29. Please Rate the Following:
S=Satisfactory M=Marginal U=Unsatisfactory
30. Does the POTW have an adequate data management system to run the pretreatment program?
Explain es or No. Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain Sampling fees billed to SIU.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e g.. odor, plant closing, new or proposed plants)? No
If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? No
If yes, Explain procedure. If no, How would the request be addressed? Will let them look at public files.
34. Does the POTW have a procedure in place that addresses requests by an industry for certain information to remain confidential')
Yes If yes, Explain. Short form has a statement that they would hold info confidential (such as trade secrets) if requested.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes, Meets with them
when sampling done at least semi-annually and annual inspection.
36. Is the public notified about changes in the SUO or Local Limits? Yes Would be on council agenda and reported in paper.
37. Were all industries in SNC published in the last notice? NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and
therefore require a permit? (Who is an SILT?) Short form is given to anyone applying for new water service,
business license, building permit or rezoning request. Planning Coordinator reviews survey with new facilities.
39.Does the POTW receive waste from any groundwater remediahons (petroleum, CERCLA) or landfill leachate? Yes
Filename: Pittsboro Audit Report'04revised
Page 3
Revised: 06/30/98
Ratin
Explanation, if Unsatisfactor
Personnel Available for Maintaining
POTW's Pretreatment Program
S
Access to POTW Vehicles for
Sampling, Inspections, and
S
Emergencies
Access to Operable Sampling
Equipment
S
Availability of Funds if Needed for
S
Additional Sampling and/or Analysis
Reference Materials
S
Staff Training (i e. Annual and
S
Regional Workshops, Etc.
Computer Equipment (Hardware and
S
Software
30. Does the POTW have an adequate data management system to run the pretreatment program?
Explain es or No. Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain Sampling fees billed to SIU.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e g.. odor, plant closing, new or proposed plants)? No
If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? No
If yes, Explain procedure. If no, How would the request be addressed? Will let them look at public files.
34. Does the POTW have a procedure in place that addresses requests by an industry for certain information to remain confidential')
Yes If yes, Explain. Short form has a statement that they would hold info confidential (such as trade secrets) if requested.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes, Meets with them
when sampling done at least semi-annually and annual inspection.
36. Is the public notified about changes in the SUO or Local Limits? Yes Would be on council agenda and reported in paper.
37. Were all industries in SNC published in the last notice? NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and
therefore require a permit? (Who is an SILT?) Short form is given to anyone applying for new water service,
business license, building permit or rezoning request. Planning Coordinator reviews survey with new facilities.
39.Does the POTW receive waste from any groundwater remediahons (petroleum, CERCLA) or landfill leachate? Yes
Filename: Pittsboro Audit Report'04revised
Page 3
Revised: 06/30/98

If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. Groundwater remediation at Cary Oil Site.
40. Does the POTW accept waste by (circle if applicable) Truck or Dedicated Pipe? No High fees eliminate requests.
41. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) NA
42. How does the POTW allocate its loadings to industries? Circle One
1.) Uniform Limits 2.) Historical Industry Need 3.) By Surcharge .) Categorical Limit 5.) Other
Explain Other:
43. Review copies of current allocation tables for each WWTP. Are there any over allocations? Yes
If yes, What parameters are over allocated? Mercury based on EPA Method 245.1
44. If yes to #43, What is being done to address the over allocations? (short term IVPs, HWA to be revised, pollutant study, etc )
Using EPA Method 1631 sampling and analyses will be done in 2007 as part of NPDES Renewal for 2008. This will
likely generate actual levels and eliminate current apparent over allocation.
45. Does the POTW keep pollutant loading in reserve for future growth / safety?
If yes, what percentage of each parameter % Plenty in reserve now. Lowest available is 29% for Nickel.
46. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) NO
If yes, Explain.
47. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Use categorical limits.
48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
Meet Categorical and NPDES Permit Requirements.
Permit C
49. Does the POTW currently have or during the past year had any permits under adjudication? No
If yes, Which Industries, and what was (will be) the outcome of the adjudication?
50. Demonstrate how the POTW fudges compliance. This should include compliance judgment on all violations of lunits, reporting
requirements, and perrnit conditions, as well as for SNC. Check data against permit. There has never been a limits violation,
only a reporting violation a few years ago.
51. Does the POTW use the Division's model inspection form or equivalent? Yes / No
If no, Does the POTW form include all DWQ data?
52. Were all SIUs evaluated for the need of a slug and spill control plan during their most recent inspections? Yes
If no, Explain. Plan on file.
53. What criteria are used to determine if a slug control plan is needed? State Guidelines. SIU is required by POTW to submit.
Filename: Pittsboro Audit Report'04revised
Page 4
Revised: 06/30/98

54. 'What criteria does the POTW use to review a submitted slug control plan? In place already. Used State guidelines
55. How does the POTW decide where the sample point for an SIU should be located? Determined by inspection. Sampling
locations are at end of process and at combined (sanitary & process) point.
56. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: swirling the sample bucket uniformly) Yes
If yes, Explain. Perry Dunn does POTW sampling. He has met with lab that does SIU sampling and observed their
procedures. (Environment One & SIMA Labs)
57. Who performs sample analysis for the POTW for
Metals: Environment One or SIMA
Conventional Parameters: Environment One or SIMA
Organics: Environment One or SIMA
58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. In house is only for process control
POTW uses commercial lab form of outside analyses (3 copies)
Long Term Monitoring Plan (LTMP) and Headworks Analysis (HWA)
59. Is LTMP maintained in a table? Excel Sheet
Review Data and Explain. The STMP data was reviewed at the last inspection. No new data to review. The next round of
STMP sampling will begin in 2007 for the HWA due in 2008.
60. Do you complete your own headworks analysis (HWA) Yes
If no, Who completes your HWA?
61. Do you have plans to revise your headworks in the near future? No. Next due 2008.
If yes, What is the reason for the revision? (circle one)
1.) Increased average flow 2.) NPDES limits change 3.) Other
4.) More LTMP data available 5.) Resolve over allocation 6.) 5 year expiration
Explain.
62. In general, what are the most limiting criteria of your HWA? NPDES Limits Pass through
63. Do you see any way to increase your loadings in the future (Example: obtaining more land for sludge disposal)? Yes
Explain.
Reuse program that will send to a local quarry (3M) to generate steam for cleaning product. This will reduce discharge
volume.
Summary
64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Bids to be issued for plant upgrade- Reuse at industry (quarry) for steam. Also, plan to add 2 larger clarifiers and
improvements to filters and UV system. Capacity will not increase, but discharge will decrease due to reuse.
Filename: Pittsboro Audit Report'04revised
Page 5
Revised: 06/30/98

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS)
65. User Name
1. Hydro Tube, Inc. 2.
3.
66. IUP Number
0001
67. Does File Contain Current Pernut?
Yes
68. Permit Expiration Date
7/31/2007
69. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
70. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes
71. Does File Contain an Inspection Completed Within Last Calendar Year?
F Yes
72. a. Does the File Contain a Slug Control Plan?
b. If No, is One Needed9 (See Inspection Form from POTW)
a.Yes
b.
a.
b.
a.
b.
73. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
Organic Management Plan (TOMP)?
Yes
74. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes
Lb. Yes
a.
b.
a.
b
75. During the Most Recent Semi -Annual Period, Did the POTW Complete
it's Sampling as Required by IUP?
No
7�1
76. Does File Contain POTW Sampling Chain -Of -Custodies?
Yes
77. During the Most Recent Semi -Annual Period, Did the SIU Complete its
SamplinE as Required by IUP?
No
78. Does Sampling Indicate Flow or Production? Flow
Yes*
79. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Non -Compliance from Both POTW and SIU Sampling?
NA
80. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resam le Within 30 Days?
a. NA
b.
a.
b.
a.
b.
81. Was the SIU Promptly Notified of Any Violations Per ERP)?
NA
82. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
No
83. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTWs ERP?
NA
84. Does the File Contain Penalty Assessment Notices?
NA
85. Does The File Contain Proof Of Penalty Collection?
NA
86. a. Does the File Contain Any Current Enforcement Orders?
b. Is SILT in Compliance with Order?
a. No
b. NA
a.
b
a.
b
87. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
No
FILE REVIEW COMMENTS:
*73- Slug/Spill Plan covers TOMP SIU certifies monthly with flow reports.
*75- Check trichloroethylene analyses- OHWA
Drop EPA Method 624/625 (TTO sampling) because SIU certifies no discharge each month. Last half of 2003 POTW did
not sample because SIU did sampling. Misunderstanding regarding sampling requirements. See *77
*76- Samples stored in iced cooler for lab pick-up. Usually, not always, Perry Dunn sees lab personnel.
*77- SIU did not do first half 2004 sampling as required in IUP. This was due to misunderstanding of 1/6 months sampling
requirements. Both parties thought only one of them had to sample every six months. POTW will do all future sampling
and likely remove SIU sampling requirements from IUP.
*78- Flow data submitted monthly
Filename: Pittsboro Audit Report'04revised
Page 6
Revised: 06/30/98

Audit SUMMARY AND COMMENTS:
Great improvement in record keeping over the past couple of years.
Need to update SUO & ERP
Modify IUP sampling requirements. POTW must sample every 6 months. (SIU is not required to do additional sampling unless
POTW feels it must) The sampling by SIU may be removed from IUP if POTW deems acceptable.
NOD: No
NOV: No
QNCR: No
POTW Rating:
Satisfactory X Marginal UnSatisfactory
Audit COMPLETED BY: Deborah Gore & Jerry Rimmer DATE: 09 /08/2004
INDUSTRY INSPECTION PCS CODING:
Trans Code Main Program Permit Number MM/DD/YY Inspec.Type
I_ NJ I N I C 1 0 1 0 1 2 10 13 15 14 I 1091081041 I I
(DTIA) (TYPI)
1. Industry Inspected: Hydro Tube, Inc.
2. Industry Address: 1755 Hillsboro Street, Pittsboro, NC
3. Type of Industry/Product: Metal Tubing (exhaust pipes)
4. Industry Contact: Gary Cogar & Tim Althaus Title: Maintenance Supervisor
Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? Yes
Inspector
Fac. Type
L S I
L 2 J
(INSP)
(FACC)
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? Perry Dunn had completed
inspection just one month prior so this was abbreviated inspection.
Comments:
A. Initial Interview Perry Dunn explained purpose of visit.
B. Plant Tour Plant tour included active manufacturing floor and pretreatment system.
C. Pretreatment Tour Pretreatment system was explained by operator.
D. Sampling Review Did not review sampling with SIU this was done at office and at recent inspection.
E. Exit Interview Thanked SIU personnel and did not have any new findings for SIU. Told them about the
sampling changes, which will be implemented with a permit modification.
Industrial Inspection Comments:
Mr. Dunn has good rapport with SIU personnel even though he only visits facility for sampling and inspections.
SIU appears to have a good understanding of what is expected of them.
Filename: Prttsboro Audit Report'04revised
Page 7
Revised: 06/30/98

United States Environmental Protection Agency
Form Approved
EPA Washington, D C 20460
OMB No 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 INI 2 U 31 NCO020354 1 11 121 04/09/08 1 17 18 U 19121 20I
u U L.J u U
Remarks
2111111111111111111111111111111111111111111111II166
Inspection Work Days Facility Self-Monitoring Evaluation Rating 81 QA -------------------------Reserved--------------------
671 1 69 70 U 71 U 72 E 73 U 74 751 I I I I I Li
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
Pittsboro 47WTP
09.00 1,14 04/09/08
02/02/01
Exit Time/Date
Permit Expiration Date
Small St Extension
Pittsboro NC 27312
11.15 AM 04/09/08
06/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Perry RJ Dunn, FO Box 759 Pittsboro NC 27312/ORC/919-542-'L444/919542 acted
o0
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jerry Rimmer RRO WQ//91957147000?.35/919-571-4718
p
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yr/mo/day Inspection Type
31 NC0020354 I11 121 04/09/06 117 18 LGJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
See Attached Pretreatment Audit form & letter.