NC0021873_Compliance Evaluation Inspection_20180702

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ROY COOPER
/IC
Governor
MICHAEL S.REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
July 2, 2018
Ms. Leesa Hopper, Town Manager
Town of Mayodan
210 W Main Street
Mayodan, NC 27027-2019 ,
Subject: Pretreatment Compliance Inspection Report RECEIVED/DENRJDWR
Notice of Deficiency# NOD-2018-PC-0206
NPDES Permit# NC0021873 JUL 7 201
8
Mayodan WWTP, Rockingham County Water Resources
Permitting Section
Dear Ms. Hopper:
On June 11, 2018, Paul DiMatteo and Kelli Park of the Division of Water Resources Winston-Salem
Regional Office conducted a Pretreatment Compliance Inspection at the above referenced wastewater
treatment system. The purpose of this inspection was to determine the effectiveness of the Town's
pretreatment program,which included: reviewing the files, POTW plant performance, sampling and
compliance judgement program, and adherence to the enforcement response plan (ERP).
Background
The Town operates a 4.82 MGD facility, and has three significant industrial users (SIUs), one of which is
categorical: Sans Technical Fibers; Unifi Corporation; and Strum, Ruger&Company.
POTW Interview
In 2017,the Town issued one Notice of Violation to Strum, Ruger&Company for neglecting to
complete its routine semiannual monitoring. However, the opinion of the Division is that the violation should
have been considered Significant Noncompliance because the SIU failed to complete 75% of the routine
monitoring required by the industrial use permit for that compliance period. Furthermore, Ms. Blackwell said
that they did not identify or act on the violation until nearly 6 months after the reporting period closed. Please
note that the approved Enforcement Response Plan for the POTW states that reporting violations are to be
addressed within 30 days of the report due date.
Part IV, Section D.9 of the NPDES Permit requires that the Permittee enforce and obtain appropriate
remedies for violations of established pretreatment requirements, and that all remedies, enforcement actions
and other shall be consistent with the Enforcement Response Plan approved by the Division. Neglecting to
take appropriate action within the time frame specified in the ERP has resulted in this Notice of Deficiency.
r::::7—Nothing Compares:"-.1.._
State of North Carolina I Environmental Quality
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone]

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You are encouraged to contact the pretreatment staff of the Winston-Salem Regional Office or PERCS unit if
you have any questions regarding the implementation of the ERP.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on September 25, 2015 and was approved on
December 17, 2015.The next HWA is due on September 30, 2020.
The last Industrial Waste Survey (IWS)was submitted on October 17, 2013 and was approved on
November 22, 2013.The next IWS is due October 1, 2018.
The last Long Term Monitoring Plan (LTMP) was submitted on March 22, 2017 and approved on June
14, 2017.
The Sewer Use Ordinance (SUO) was approved on February 21, 2013.
The ERP was approved on December 27, 2012.
LIMP Review
The LTMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
All IUPs expire on June 30, 2021. The SIU files, chain of custody and lab reporting are in excellent order.
Action Items
Please submit the IWS by October 1, 2018. Ms. Blackwell said that the information was being compiled.
The next pretreatment annual report will be due by March 1, 2019.
If you should have any questions regarding this report, please do not hesitate to contact Paul DiMatteo
at [phone] or our office at [phone].
Sincerely,
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures—PCI Report
CC: Nadine Blackwell, Pretreatment Coordinator, PO Box 1279, Clemmons, NC 27012
PERCS Unit—Monti Hassan
WSRO Files
Central Files

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NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
V,tef Rcsc.irces
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: Mayodan WWTP
2. Control Authority Representative(s): Nadine Blackwell Jamie Whitten G. Moore
3. Title(s): Pretreatment Coordinator,WWTP ORC,Backup-ORC respectively
4. Last Inspection Date: 6/27/2016 Inspection Type(Check One): ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ®NO
Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number MM/DD/YY
N1_ C10101 211 1817131 1061111181
7. Current Number Of Significant Industrial Users(SIUs)? 3
8. Number of SIUs With No IUP,or With an Expired IUP? 0
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.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods? 0
12.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods? 0
13.Number of SIUs in SNC with Pretreatment Schedule? 0
14.Number of SIUs on Schedules? 0
15.Current Number Of Categorical Industrial Users(CIUs)? 1
16. Number of CIUs in SNC? 1 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? Z YES ❑ NO
If Yes,What are the Parameters and How are these Problems Being Addressed? Fecal violations—not related to
industry.
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 for Limits or Reporting during SNC for Limits.None
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:None
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? None
21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑ YES ® NO
Ones?
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25 All LTMP/STMP effluent data reported on Discharge Monitoring Report? ®YES❑NO Division Inspector,please verify yourself!
26. IfNO to 23-26,list violations (Reviewed 1/2018 and 6/2016 DMRs)
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO
If yes,which ones?Eliminated: Will be reevaluated after NPDES permit renewal. Added:
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 9/25/2015 ®Yes ❑ No 12/17/2015 ®Yes ❑ No 9/30/2020
Industrial Waste Survey(IWS) 10/17/2013 ® Yes ❑ No 11/22/2013 ®Yes ❑ No 10/1/2018
Sewer Use Ordinance(SUO) 2/4/2013 ® Yes ❑ No 2/21/2013 ®Yes ❑ No
Enforcement Response Plan(ERP) 12/20/2012 ®Yes ❑ No 12/27/2012 ®Yes ❑ No
Long Term Monitoring Plan(LTMP) 3/22/2017 ® Yes ❑ No 6/14/2017 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Sans Technical 2. Unifi 3.Strum,Ruger&Co
30. IUP Number 108 105 109
31. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 06/30/2021 6/30/2021 6/30/2021
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A N/A 433
34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan? a. ®Yes❑No a. ®Yes❑No a. ZYes ❑No
b.If No, is One Needed?(See Inspection Form from POTW) b. ['Yes EINo b. ❑Yes ❑No b. ❑Yes❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
Organic Management Plan(TOMP)? Industry Samples
38. a. Does File Contain Original Permit Review Letter from the Division? a. ®Yes❑No a. ®Yes ❑No a. ®Yes LINO
b.All Issues Resolved? b®Yes❑No❑N/A b.®Yes❑No❑N/A b,®Yes❑No❑N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No
41. During the Most Recent Semi-Annual Period,Did the SIT Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b.During the Most Recent Semi-Annual Period, Did SIU submit all reports ®Yes❑No❑N/A NYes❑No❑N/A ®Yes❑No❑N/A
on time? _
42a. For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑NoE1N/A ❑Yes INo N/A ❑Yes❑NooN/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include ❑YeS❑No N/A ❑Yes❑No NN/A ❑YesDNo N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ® Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify NYes❑No❑N/A NYes❑No❑N/A NYes❑No❑N/A
All Reporting Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU(Within 24 Hours)of AlI Self- a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days? b❑Yes❑No®N/A b❑Yes❑No®N/A b❑Yes❑No®N/A
c. If applicable,Did POTW resample within 30 days of becoming aware c❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU? c❑Yes❑No®N/A c❑Yes❑No®N/A
46. During the Most Recent Semi-Annual Period, Was the SIU in SNC? ❑ Yes ® No ❑Yes ® No ❑ Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑YesDNoNN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
as Specified in the POTW's ERP(NOVs, Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No EN/A ❑Yes❑NoNN/A NYes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No EN/A ❑YesDNoEN/A NYes❑No❑N/A
50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ® No ❑Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

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FILE REVIEW COMMENTS: Files were well organized and readily available.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 1 1 1 1 1 1 1 I I I l i t
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:
Not conducted during PCI.
OVERALL SUMMARY AND COMMENTS:
Comments: During the inspection it was noted that Ruger missed their routine sampling for the first semi-annual period of 2017,and that the
violation was not addressed by the POTW until it was preparing the Pretreatment Annual Report in 2018.Ms.Blackwell explained that the
industry completed the additional sampling required due to being in significant noncompliance in the 2nd semi-annual period of 2016,but forgot
to do the routine monitoring.Please note that Mayodan's Enforcement Response Plan specifies that reporting violations be addressed within 30
days of the report due date.
Requirements:Identify and respond to reporting violations as specified in the Enforcement Response Plan.Contact the Winston-Salem Regional
Office or the PERCS unit if there are any questions regarding implementation of the ERP.
Recommendations:
NOD: E YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory Marginal UnSatisfactory
PCI COMPLETED BY: ?AAA WDATE: bill l -2,0)4
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3