NC0037508_Compliance Evaluation Inspection_20190304

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MICHAEL S.REGAN ' P�RI�VV�q
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Director Water Rezource,
Fwmitting Section
March 04, 2019
Janna Nall
Moore County
1094 Adder Rd
Aberdeen, NC 28315
SUBJECT: Pretreatment Compliance Inspection Report
Moore County WPCF
NPDES WW Permit No. NC0037508
Moore County
•
Dear Mrs. Nall:
Enclosed please find a copy of the Pretreatment Compliance Inspection form from the inspection conducted on
February 28, 2019. The Pretreatment Compliance Inspection was conducted by Johnathan Watts, Environmental
Specialist, of the Fayetteville Regional Office.
The purpose of the pretreatment inspection is to determine the effectiveness of the Pretreatment program by
reviewing the files, which include a review of POTW plant performance, sampling and compliance judgment program,
adherence to the enforcement response plan (ERP), and evaluating how the program performs an industrial user
inspection.
This PT Inspection report indicated that the City of Raeford Pretreatment Program met the pretreatment
requirements as outlined in 15A NCAC 2H .0900
The inspection report is attached with findings and observations made during the inspection. Please review
for more detail.
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If you should have any questions, please do not hesitate to contact Johnathan Watts with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3322 or via email at
johnathan.watts©ncdenr.gov.
Sincerely,
J. Trent Allen, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: PERCS Unit
FRO Pretreatment Files (JW)
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United States Environmental Protection Agency Form Approved.
E PA 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
I H 2 15 1 3 I NC0037508 111 12 I 19/02/28 117 18[o I 19 I G J 20I
211111 I I I I I III I I I I I I I I I I I I I I I I I I I I I I III I I I I I r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -Reserved
67I I 70I I 711
I 72 Li
731 I 174
1 I I I I I I I80
Section B.Facility Data L--
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) 09 30AM 19/02/28 16/11/01
Moore County WPCF
Exit Time/Date Permit Expiration Date
1094 Addor Rd
12 45PM 19/02/28 21/10/31
Aberdeen NC 28315
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
Contacted
George Yankay,1094 Adder Rd Aberdeen NC 28315/1910-281-3146/
No
Section C.Areas Evaluated During Inspection(Check only those areas evaluated)
III 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
Johnathan C Watts FRO WQ//910 433-3300/ 6.- L1 '3-4_n
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Trent Allen FRO WQ//910-433-3300/ -, 4,�,� 1/2A
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type (Cont) 1
ti3I NC0037508 J11 121 19/02/28 117 18 f
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Moore County has three(3)significant industrial users(SlUs),three of which are categorical and is a
10 MGD permitted facility.
One permit file was reviewed The pretreatment inspection file review included Thermal Metal Treating.
Thermal Metal is a categorical significant industrial user that uses process wastewater from
electroplating and metal heat treating services. The inspection included a thorough review of all areas
and all areas of chemical storage.
The Division of Water Resources commends Mrs. Flowers for her initiative and proactive approach
towards documentation and monitoring. Mrs. Flowers is implementing the Pretreatment Program in a
consistent and professional manner and the time and professional courtesy she extended during the
inspection is greatly appreciated
In order to update records with the Division of Water Resources, please complete and submit the
enclosed change of ownership form with the current information to reflect the correct responsible
official.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me by phone at(910)433-3322 or email at [e-mail] if you have any
questions or concerns.
•
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
h'uterRe,ourres
LIVIriOTIMENTAL aunLn
BACKGROUND INFORMATION[Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: Moore County
2. Control Authority Representative(s): Connie Flowers
3. Title(s): Lab Supervisor
4. Last Inspection Date:_06/13/2017_Inspection Type(Check One): I 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
J NJCIO J 0 1 3 1 7 1 5 1 0 1 8 L J02128 [19J
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)? 3
16. Number of CIUs in SNC? 1 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ®YES ❑NO
If Yes,What are the Parameters and How are these Problems Being Addressed? Please see Overall summary
and Comments.
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:0
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:0
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: 0
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?
LIMP/STAR 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 yourselfl
26. If NO to 23-26,list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑YES ®NO
r,�rm„_ +n r o r cr,Ant;r,.,(POT\Pr rn, TTnd ated 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) 12/11/2014 ®Yes❑ No 03/12/2015 ®Yes❑ No 01/31/2020
Industrial Waste Survey(IWS) 09/04/2013 ®Yes❑ No 11/15/2013 ®Yes❑ No 09/01/2023
Sewer Use Ordinance(SUO) 10/19/2012 ®Yes❑ No 10/22/2012 ®Yes ❑ No
Enforcement Response Plan(ERP) 10/30/2008 ®Yes❑ No 11/19/2008 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 08/24/2018 ®Yes❑ No 09/26/2018 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Thermal Metal Treating 2. 3.
30. IUP Number A008
31. Does File Contain Current Permit? ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
32. Permit Expiration Date 06/30/2020
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or 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. EYes❑No a. ❑Yes❑No a. ❑Yes ❑No
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ❑No b. ❑Yes ❑No b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No 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
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 SIU 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 ❑Yes❑No❑N/A ❑Yes❑No❑N/A
on time?
42a.For categorical Ws with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b.For categorical Ms with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑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 ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
All Reporting Non-Compliance from SIU Sampling?
44. a.Was the POTW Notified by SIU(Within 24 Hours)of All 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 ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No EN/A ❑Yes❑No❑N/A ❑Yes❑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

FILE REVIEW COMMENTS:
All files were available for direct access.Excellent records management.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
JNICLO101317 [510181 I02128119F
1.Industry Inspected: Thermal Metal Treating Inc
2.Industry Address: 9546 NC 211/PO Box 367 Aberdeen NC 28315
3.Type of Industry/Product: Nickel electroplating and Metal heat treating
4.Industry Contact: Bruce Powell - Title: Process Control-Operator
Phone: [phone] Fax: [phone]
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
OVERALL SUMMARY AND COMMENTS:
Comments: 1.Excellent record keeping and organization.
Question #17. Moore County WWTP had limit violations during the month of April in 2018 for BOD monthly average. During the
reconstruction and replacement efforts of Addor Road Bridge,contractors had to stall water services for 30 days as new water line was installed.
As a result,Moore County WWTP had to utilize other resources to obtain water and meet demand at the plant. All other NPDES violations
were during the month of September 2018 and reflect the relevance of Hurricane Florence.
Requirements:None
Recommendations:None
NOD: ❑YES ®NO
NOV: ❑YES ®NO
QNCR: ❑YES ®NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Johnathan Watts,Fayetteville RO DATE: 02/28/2019
NC DWR Pretreatment Compliance Inspection(PCII Form Updated December 2016 Page 3