NC0025054_Pretreatment Audit Report_20191030

ROY COOPER
r�vrivo.
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Dir,?ir: i
Mr. Antoine Lewis
WWTP Superintendent
City of Oxford
P.O. Box 506
Oxford, NC 27565
Subject: Pretreatment Audit
r ?TH CAROUNA
Environmental Quality
October 30, 2019
City of Oxford
NPDES Pen -nit No. NCO025054
Granville County
Dear Mr. Lewis:
On September 11, 2019, Vivien Zhong of Pretreatment, Emergency Response, and Collection
Systems (PERCS) Unit and Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Audit of City of Oxford's pretreatment program. Tile assistance given by you and
Ms. JoAllen Gay, the City's pretreatment consultant, was greatly appreciated. The audit report is
attached. Findings during the inspection were as follows:
1. The City has three Significant Industrial Users (SIUs), one of which is also Categorical
Industrial Users (CIUs). It was noted that none of the SIUs was in Significant Non -
Compliance (SNC) for the two most recent semi-annual period.
2. The pretreatment audit file review included Certain Teed (Pen -nit No. 0102), Lace Lastics
(Permit No. 0112), and Revlon (Permit No. 0108). The files needed for review were
available for inspection, contained all the required elements and were in excellent
condition.
3. POTW and SIUs completed monitoring as required by the Industrial User Pretreatment
Permits (IUPs) during the most recent semi-annual period. All SIUs were in compliance.
4. During the audit, Mr. Antoine Lewis and Ms. Gay inspected one of the SIUs, Lace
Lastics. The inspection was very thorough.
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review of the files containing the pretreatment program elements was conducted.
- These files were very well organized. It was noted that Headworks Analysis was updated
_._.. gyed in 2018. Update of Industrial Waste Survey is due September 1, 2020.
b. The review of LTMP data indicated that all locations were sampled with required
frequencies, and all samples were analyzed using correct detection limits specified in the
LTMP since last inspection.
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: cheng.zhang,Ck-nederingov).
Sincerely,
iN ,, ,
'�' -, � r. '�
S. Jay Zimmennan, P.G., Chief
Water Quality Regional Operations Section
Enclosure: 2019 City of Oxford Audit Report
CC: Vivien Zhong, DWR - FPERCS Unit
Cheng Zhang - RRO
Central Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)
I. Control Authority (POTW) Name: City of Oxford
2. Control Authority Representative(s): Antoine Levis
3. Title(s): WNVTP Superintendent
4. Address of POTW:
Mailing PO Box 506
City Oxford Zip Code 27565
Phone Number J919 )693-8783 Fax Number [phone] E-Mail ale►vis!d oxfordne.oru
5. Audit Date 0911,2019
6. Last Inspection Date; 07'1 I+2018 Inspection Typc: ®PCI ❑ ;audit
7. Has Program Completed All Requirements from the Previous Inspection and Pro.,rani Info Sheet(s)9 ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance probtems'? ®Yes ❑Nr,
If Yes, Explain. Experienced a weather related NI13 ►iolation
9. Is POTW under an Order That Includes Pretreatment Conditions'? ❑ 1'es ® No
Order Type and Number: Are Milestone Dates Being filet? ❑ Yes ❑ No E NA
Parameters Covered land%r Order
ICIS Coding
Main Program Permit Number
iV I C 01.012 S 10 1 S 14
.WN1 DD YY
A2-i I I I 19
10. Current Number of Significant Industrial Users (SIUs)!
11. Number of SiUs ivitlt No lUP, or with an Expired IUP?
..............
12_ Number of SIUs Not Inspected by POTW in Last Calendar Year!
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
14. Number of SIUs in SNC for Limits Violations Durint, Either of Last 2 Semi -Annual Periods`? .................. .
15. Number of SIUs in SNC for Reporting During father of Last 2 Semi -Annual Periods`!
16. Numb%rofSlUs in SNC with Pretreatment Schedule?
......... ........
17. Number of SIUs on Schedules'?
.............
...................... .
.................. .
18. Current Number of Categorical Industrial Users (C4Us)7
............. .
19. Number of ClUs in SNC?

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
„ thwir Fit.. rn h-t, u;ih all cnynrl PCR('S Annrnval nntt mares ennvis1en1 Lvi1h Prorrram Info_
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicabie
Ilead►vorks Analysis (IiWA)
06/18/2018
El Yes No
07/11/2018
LXJ Yes LJ No
08/01/2023
Industrial Waste Survey (IWS)
08/25/2015
Yes No
09/01/2015
Yes 0 No
09/1/2020
Se►►cr Use Ordinance (SUO)
11105/2012
Yes No
12/14/2012
Yes No
Enforcement Response Plan (ERP)
06/08/2010
Yes No
08/30/2010
Z YesLJ No
Long Term Monitoring Plan (LTMP)
07/11/2017
YNo
08/04/2017
Z Yes No
Legal Authorit • (Sover Use Ordinance-SUO)
21_ Do you have any towns and:or areas from which you receive wastewater which are not in your annexed jurisdiction'?
❑ Yes ® No If yes, Please list these towns and -or areas.
22. If yes to t72I, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts`? ❑ 1'es ❑ No ®NA
A copy, if not already submitted, should be sent to Division.
23. If yes to r?21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 10-09 2012
25. I -lave you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcemen( Response Plan-ERP)
26. Did you send a copy of the ERP to your industries'? ® Yes ❑ No
If no, POTW must send copy ►►ithin 30 days.
27. 1-lave you had any problems interpreting; or enforcing any part of the ERP (i.e. any adjudication. improper enforcement, etc`?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and "Type of Schedule or Order
NIA
Resources
29. Please Rate the Following: S=Satisfactor NI -Marginal U-.Unsatisfactory
RatiIt g
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑NI ❑U
Access to POTW Vehicles for
Sampling;, Inspections, and
®S ❑m ❑U
Emergencies
Access to Operable Sampling;
Equipment
®S ❑m ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑m ❑u
Staff Training; (i.e. Annual and
Regional Workshops, Etc.)
®S ❑,NI ❑U
Computer Equipment (Hardware and
Software)
®S ❑m ❑U

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel Spreadsheet for data management and compliance judgement.
3 I. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges
Public Perception! Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed`? tales only maintained onsite at the «'WTP. One could
call or walk in to request to view files.
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Filed could be kept separate if requested.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment`? ® Yes ❑ No
If changes anticipated.
36. Is the public notified about changes in the SUO or Local Limits'? ❑ Yes ® No SUO is online
37. Were all industries in SNC published in the last notice'? ❑ Yes ❑ No \!A
Permitting (Industrial Waste Survev-I«'S)
38. !-low does the POTW become aware of new or changed Users? Water Billing Department, Newspaper ads and articles
39. Once the POTW becomes aware of new or changed Users, how does the POI «` determine ►►hich industries have the
reasonable potential to adversely impact the WWTP and therefore require a new pennit or a permit revision? (Who is an
SIU'?) \Iail IUP short form industry and perform inspection if necessary to determine if [UP long form needs to be
mailed for possible permitting. Categorical determination, look at flow quantity, and ► hether or not 5% of
maximum allowable head►torks loading for SIU determination.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CL'RCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there'? Two
Please list each site and how it is permitted, if applicable_ .1PD Electronics and Granville County Landfill. Samples
are taken from tanks prior to hauling. Random samples are pulled from leachate tracks.
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Require Septic tank haulers to log load including address and volume.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ®Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there anv over allocations? ❑ Yes ® No
If yes, what parameters are over allocated'? NA *.NIercury :.NEVI, ►►as negative because the uncontrollable was
calculated using higher detection level data.
45. If yes to 444, What is being done to address the over allocations'? (short-term IUPs, I IWA to be revised, pollutant study, etc.)
NIA *SIUs started to use lover detection level for ntercurv.
46. Does the POTW keep pollutant loading in reserve for future growth / safety'! ® Yes ❑ No
If yes, what percentage ofeach parameter now available Grenter-Than >50'X., probably want to reserve at least 30%
47, Has the POTW experienced any difficulty in allocation'? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain. NIA

48. 1-low 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)
NPDES POCs, Categorical parameters, and local limits, such as oil and grease monitoring. Historical data, baseline
buildup to make a decision.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain -
Based on risk of harm, surcharges, Ileadworks Analysis, and to comply with the required frequencies of Pretreatment
Regulations. If a new IU, frequency would be increased to establish a baseline.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication'' ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication'?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance is determined with every sampling event for limits and
reporting. If there are violations, we follow the ERP. At the end of a SA period, we judge compliance for each IU. We
follow the State policy for a violation and a TRC violation for Significant Non -Compliance determination.
52, Does the POTW use the Division's model inspection form or equivalent'? ® Yes ❑ No
If no, does the POTW form include all Division data" ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug -spill control plan during their most recent inspections'? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug:spill control plan is needed!
Bulk storage of chemicals, process wastewater, and other non -domestic streams and their location with relationship to floor
drains, manholes, etc.
55. What criteria does the POTW use to determine if a submitted slug spill control plan is adequate''
Adequacy of response to spill/slug and notification procedures of personnel of whom to call at PO I NV should spill?slug
reach sanitary sewer.
56. flow does the POTW decide where the sample point 1'or an SIU should be located?
Either at end of process discharge or at the last manhole prior to entry to our system that is representative of the discharge.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No if yes, Explain. Both POTNV and SIU collect own samples that are
run by a commercial lab.
53. Who performs sample analysis for the POTW for
Metals Meritech Laboratory
Conventional Parameters Meritech Laboratory
Organics Meritech Laboratory
59- Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
COC for each plant site is pre -filled, write in date, time, collector, time relinquished, etc. If split samples, obtain
signatures front IU.
Long/Short Term Monitoring Plan (LIS'rMP) and Ileadw•orks Analysis (II11'A)
60a. Is LTNIPrSTNIP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTIMP. STNIP Monitoring? ® YES ❑ NO
60c. Is LTNIP.:STNIP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate'? ® YES ❑ NO
60d. All LTNIP.:STMP effluent data on. Discharge Monitoring Report (DNIR)? ® YES ❑ NO Di%ision Inspector, verify yourself?
60e. if NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to L`I-NIPYSI'NIP? ❑ YES 0 NO
If yes, which ones" Eliminated: Added,.
61. Do you complete your own lleadworks analysis (I.IWA) '? © Yeti ❑ No
If no, who completes your HWA? Pltone ( )

62. Do you have plans to revise your 1IWA in the near future'? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased aNerage flow ❑NPDES limits change
❑Vlore LTNIP data available ❑Resolve over allocation ❑5 year expiration ®Other
Explain. When NPDES permit is rene«ved.
63. In general, what is the most limiting criteria of your I IWA? ®Inhibition ® Pass Through ®Sludge Quality ALL THREE
ARE EQUALLY LIMITING
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Sumrnanti
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment'?
No

INDUSTRIAL USER PERMIT ([UP) I:ILE REVIENV (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Certain Teed 2. Lace Lastics IF
3, Revlon
67. IUP Number
0102
0112
0108
68. Does File Contain Current Permit?
Yes No
I N Yes L1 Nv
Yes Ll No
69. Permit Expiration Date
12-31,22
i2131?22
12 31 '22
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N A
443.36
ti rA
`/A
71. Does File Contain Permit Application Completed Within One Year Prior
0 Yes 0No
Yes ElNo
YcsLj No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
I Z Yes 0 No
Yes No
_ Yes Lj No
73. a. Does File Contain Slug'Spill Control Plan'?
a. ®Yes ❑No
Fb_
a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Y,es❑tics®\
❑Yes❑NOON A
❑1'es❑NoON A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved`?
I b ❑Y«❑1ot7N A
b °Yca❑No❑N A
b ❑Yes❑ ON A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
0 Yeti Cj No
❑N'es[3%-06 A
Yes No
g Sam lin as Required b * [UP, including Flow?
11
77. Does File Contain POTW Sampling Chain-Of-Custod • Forms`?
Yes LJ No
❑Yes❑No®ti'`A
Yes Lj No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
17Ye;0tio0\
®Ycs❑\o❑N A
®Yes❑No❑NrA
Sampling as Required by IUP, including Flow'?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N .1
®YesO\o❑\ 1
OYesONo❑N A
time?
80a. For categorical ]Us with Combined Wastestream Formula (Cl\'F), does
❑Ye,❑tio(D\ A
❑N'es❑N'oGlN A
❑Yes❑No®N+"A
file include processidilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑'l"Oelti A
❑Y'es. 0%0 A
❑Yes❑No®NrA
roduction rates andior flows as Required bX IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
0N'e,.,0No x7\ A
0Ycs0\'o8N A
❑Yes❑NoON-A
Limits Non -Compliance from Loth POTW and SIU Sampling,'?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑\oGlN A
❑Yes❑NoEIN A
❑Yes❑NoON.A
Re nriin Non liance from S[U Sant ling`?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Sell'-
a.°Yc,°No0\ A
a.°Yes❑NL)mN A
a.❑YesONoON A
Monitoring Violations'?
b. Did Industry Resample and submit results to POTW within 30 Days?
t' °YciONoON `1
b ❑Yes❑NoE)N A
b.°Ycs❑NoGN A
c. If applicable, did POTW resample and obtain results within 30 days of
*
becoming aware of SIU limit violations in the POTW's Sant ling of'SIU'!
` ❑} "°%Ot3` A
c ❑Yes❑Nc®N A
e.❑Y�w°No®N A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
Ej Yes 2 No
Lj Yes No
Yes M No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
0Ycs❑tio(9 =Y
❑1'cs❑NOON A
❑Ycs❑NOON-A
S ecified in POTW's ERP (NOVs, Penalties, timing, etc.)?
11
86, Does File Contain Penalty Assessment Notices?
❑Yes❑NoEl A
❑Yes❑NoO A
❑Yes❑No®N A
87. Does File Contain Proof Of Penalty Collection'?
❑Yes❑No®N-A
❑N'es❑No®N A
❑Yes❑NOON A
88. a. Does File Contain Any Current Enforcement Orders'?
a.❑Ycy❑NoGN A
a.❑Ycs❑No®N A
a.❑Yes❑No®N A
b. Is SIU in Compliance with Order?
b ❑Y'o,❑No®ti A
b ❑Yes❑NomN A
b °Ycs❑ oON A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
LJ Yes N No
Lj Yes U No
LJ Yes M No
Information For You?
I
F
FILE REVIEW COMINI ENTS:
CertainTeed: 73, Update WWTP contact info as needed. 75. Streamlined approval letter resent on September 11, 2019.
78. SIU data sheet mercury unit was ug/L.
Lace Lastics: 76 and 77, POTW did not sample in the first six-month period of 2019, pennit requires POTW to sample once per year.

INDUSTRY INSPECTION [CIS CODING:
Main Program Permit Number MM DD 1'1'
0 1 0 -5 1 0 1 5 1 d 1 09 1 111 19
I. Industry Inspected: Lace Lastics
2. Industry Address: 610 Pine Tree Road Oxford. NC 27565
3. Type of Industry.:Product: Lacewing
4. Industry Contact: Leslie Pulliam Title: Environmental Manager Plione: 919-693-2100 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:
The inspection was thorou h and met the Division's reuttirements.
Audit SUMMARY AND COZEMENTS:
Audit Comments: The City need to hire a retreatntent coordinator as soon as possible.
Requirements: ,None
Rewmmendations. None
NOD: ❑ Yes
NOV: ❑ Yes
QNCR: ❑ Yes
POTW Rating:
® No
® No
® No
Satisfactory ® Marginal ❑ Unsatisfactory- []
Audit COMPLETED BY: Visien ZI1011g, PERCS. and Cheng Zhang, Ralei h Re ■ional Office DATE: Sentember 11. 2019