NC0024881_Pretreatment Audit Inspection_20190906

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
September 6, 2019
Mr. Ralph Potter, Pretreatment Coordinator
City of Reidsville
407 Broad Street
Reidsville, NC 27320
SUBJECT: Pretreatment Audit Inspection Report
Reidsville Wastewater Treatment Plant
NPDES Permit No. NCO024881
Rockingham County
Dear Mr. Potter,
On August 27, 2019, Paul DiMatteo of this office and Vivien Zhong of PERCS conducted a
Pretreatment Audit Inspection at the above referenced wastewater treatment system. Ralph Potter,
Pretreatment Coordinator, was present for the inspection. The purpose of this inspection was to
determine the effectiveness of the pretreatment program, which included: a detailed file review, review
of the POTW facility performance, sampling and compliance judgement program, adherence to the
enforcement response plan, and observing an industrial user inspection.
Background
The County operates a 7.5 MGD facility and has nine significant industrial users, three of which
are categorical.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on March 23, 2015 and was approved
on May 18, 2015. The next HWA is due by September 30, 2019.
The last Industrial Waste Survey (IWS) was submitted on May 28, 2019 and was approved on
July 17, 2019. The next IWS is due by April 1, 2024.
The last Long -Term Monitoring Plan (LTMP) was submitted on August 25, 2017 and was
approved on September 27, 2017.
The Sewer Use Ordinance (SUO) was submitted on October 29, 2012 and approved on
November 21, 2012.
The Enforcement Response Plan was approved on June 4, 2010.
D E Q�p North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH C. 0LINA
o•o•°^•mme""°""•"viu"•i� /� 336.776.9800

LTMP Review
The LTMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Keystone Foods (#004) and Henniges Auto (#010) and Envision Plastics
(#011) revealed that the monitoring data was well organized and the slug control plans were in good
order.
Industrial Inspection
Keystone Foods a processed food manufacturer. The inspection included a thorough review of
the plant, sampling practices, and industry self -monitoring.
The pretreatment audit is satisfactory. The program is being implemented in an excellent
manner. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-
9691 or our office at [phone].
Sincerely,
DocuSigned by:
J� T SMder
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures — PAI Report
CC: PERCS Unit — Vivien Zhong
WSRO Files
Central Files

'r
K" 1; 0,
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Reidsville
2. Control Authority Representative(s): Ralph Potter
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 407 Broad Street
City Reidsville Zip Code 27320
Phone Number 336-347-2310 Fax Number 336-349-1008 E-Mail rpotterAci.reidsvillemc.us
5. Audit Date 08/27/2019
6. Last Inspection Date: 04/04/2017 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0101 2 14 1 8 1 8 I 1
MM/DD/YY
108 127 119
10.
.................................................................
Current Number of Significant Industrial Users(SIUs)?...............................................................................................
9
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users..(CIUs)?............................................................................................
3
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File. complete with all suDDortinc documents and PERCS ADDroval Letter. and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/23/15
® Yes ❑ No
5/18/15
® Yes ❑ No
9/30/2019
Industrial Waste Survey (IWS)
5/28/19
® Yes ❑ No
7/17/19
® Yes ❑ No
4/1/2024
Sewer Use Ordinance (SUO)
10/29/12
® Yes ❑ No
11/21/12
® Yes ❑ No
Enforcement Response Plan (ERP)
3/11/10
® Yes ❑ No
6/4/10
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/25/17
® Yes ❑ No
9/27/17
® Yes ❑ No
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?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #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 10/10/12
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ❑ No
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 adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
None.
Resources
29. Please Rate the Following: S=Satisfactory M=Mareinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑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 ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Spreadsheets and electronic files. LTMP and industry data is entered into spreadsheets shortly after
receipt to facilitate completion of HWA.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Invoice for POTW sampling, surcharge waste received >300 mg/1 for BOD and TSS.
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? Requests to review files are handled by the Public Works
Director.
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? Files are locked in the pretreatment coordinator's office. Confidential
information determinations are made as described in the sewer use ordinance.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
No specific public notice, but the ordinance is available on the City's website.
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
No industries in SNC.
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Water billing records and business records. Goes
through the Public Works Director.
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SILT?) POTW considers water usage, may inspect the facility, determine if sampling is needed, and finally compare
sample results to the allocation table.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. 1 pipe from a site related to one of their metal finishers. It's
captured in the IUP as a separate pipe and has another separate document.
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) Any trucked or piped waste would need to be approved by the Public Works Director.
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: If deemed detrimental to the WWTP's biological process.
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated? No current over allocation, however, there will be a paper over allocation
of silver after the next submittal due to a difference in industry detection limits compared to the POTW.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
For the foreseen over allocation, POTW plans to update IUPs to lower limits.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10-20%
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. 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)
NPDES and sludge permit limits, SUO, water quality standards, 5% MAHL.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Based on reasonable potential and historical data. Based on reasonable potential and historical data.
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. Data is entered in a spreadsheet as received, and the sheet
automatically flags violations.
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?
Required for all SIUs.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review and compare with own knowledge of the facility. Review again before inspection and require update if needed.
56. How does the POTW decide where the sample point for an SILT should be located?
Look at process water, make sure no domestic water is being collected.
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. POTW uses all own samplers. Most SIUs have a
lab sample for them; otherwise they review procedures during the inspection.
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters Meritech
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
House/Meritech provided forms.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES ®NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60e. If NO to any above, list violations There is a discrepancy between the LTMP listed detection level for TSS and what's
reported by the lab and what's required in the Division's model LTMP (2.0 mg/1 vs 2.5 mg/1). This will be corrected during the
next LTMP revision.
60f.
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ® YES ❑ NO
If yes, which ones? Eliminated: MBAS, Oil & Grease Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone ( i --
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ®Other
Explain. Changed treatment process.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑ Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
They plan to upgrade the plant for BNR in the near future.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Envision Plastics
2. Henniges
Auto
3. Keystone Foods
67. IUP Number
O11
010
004
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
6/30/2020
6/30/2020
6/30/2020
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
428
1 N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ NoI
® Yes ❑
NoI
® Yes ❑
No
73. a. Does File Contain Slug/Spill 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. []Yes []No I
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
F
❑Yes❑No®N/A
❑Yes❑No®N/A
Organic Management Plan (TOMP)?
1
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []No
I 11
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
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
F977s ❑ No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
F
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
1
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
❑Yes®No❑N/A
®Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑ Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
amYes❑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 and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.®Yes❑No❑N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
® No
❑ Yes ® No
❑ Yes ®No
Information For You?
I[E]Yes
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I NI C1 0 1 0 1 2 14 18 18 11 1 081 27 1191
1. Industry Inspected: Keystone Foods
2. Industry Address: 227 Eguity Drive, Reidsville, NC 27320
3. Type of Industry/Product: Food Processor
4. Industry Contact: Tina Title: Phone: [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:
Very thorough inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: Very well run program.
Requirements: Submit the HWA on time.
Recommendations: Update LTMP to reflect the current standard DL for TSS.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
/DOCUSigned by:
Audit COMPLETED BY ' 10 DATE: 8/27/2019
tl—
F10 2E5B3
Vivien onBg, RC!S, and Paul DiMatteo, Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7