NC0021211_Pretreatment_Annual_Report_20200228

Titt of (�rtt tm
P. O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
February 27, 2020
Ms. Vivien Zhong
NC Division of Water Resources
PERCS Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: 2019 PAR for City of Graham
Dear Ms. Zhong,
Please find attached the City of Graham's Pretreatment Annual Report for the January 1, 2019 through
December 31, 2019 reporting period.
Should you need further information or if you have any questions regarding the report, please contact
me at 336-570-6721 or [e-mail].
Sincerely,
Shelby S. Smith
Pretreatment Coordinator
City of Graham

Narrative - 2019
City of Graham
General Information
General Program Information:
• Allocation Table, Long Term Monitoring an, Sewer Use Ordinance,
Headworks Analysis, Enforcement Response Plan, Industrial Waste
Survey and Permits are up to date. As required by the last approved
HWA on 10/3/18, City of Graham will submit an updated allocation table
with updated POTW average flow to reflect new TP loading by
September 1, 2020. City of Graham has also made some detection level
updates and added detection level language to our LTMP and it was
approved on February 13, 2020. As discussed with the PERCS office and
mentioned in our PAR Narrative for 2018, we began monitoring total
nitrogen in 2019 as specified in our LTMP for all sites specified with the
exception of plant effluent which has already been being monitored per
the NPDES permit.
• The detection level language change to our LTMP that was mentioned
above, was to address some issues already mentioned in the 2018 PAR
Narrative with the commercial lab which analyzes our metals and the
problems they are having getting the lower detection limits due to the
nature of the samples and interferences which cause major, expensive
issues with the equipment resulting in malfunctioning of that equipment
and need to revert different methods (200.7) with higher detection levels.
Our approach to handle this situation at this time is to always request the
lowest detection limits but with the understanding that the nature/matrix
of the samples, specifically industrial samples, may be unobtainable and
other methods with higher detection limits may be necessary.
Documentation, which will remain with the sampling results, will always
be required explaining these situations
The ERP for City of Graharn was updated to reflect the Dental Amalgam
Rule. This background work for the change was in process in 2019, but
the actual updated ERP was submitted to DWR on February 7, 2020 and
approved on February 14, 2020.
No SIUs were in Significant Noncompliance in 2019.
Data on the Division's Pretreatment Program Information Database has
two corrections that need to be made. These corrections are date updates
that did occur until after we received the Program Info. sheet, but I just
wanted to mention. First, the Date Received by DWR for the LTMP is
January 3, 2020 and Date Approved is February 13, 2020. Secondly, the
ERP Date Received by DWR is February 7, 2020 and Date Approved is
February 14, 2020.
General Permit Information:
• SIU Permits for Cintas Corporation, Luxfer Gas Cylinders, Novaflex
Hose, Inc. and Stericycle, Inc. are now in their fourth year of the five year
permit cycle. There were no permit modifications for these industries
during 2019.
• SIU Permit for Prescient Company, Inc. is in their third year of the five
year permit cycle. Prescient Company did not have any permit
modifications during 2019.

SFU Information
1. Cintas Corporation - Permit No. 0007 (Industrial Laundry)
610 Woody Drive, Graham, N.C. 27253
Cintas Corporation had the following activities during the Jan.l- Jun. 30, 2019 reporting
period:
• Cintas Corporation had no violations this reporting period to report.
• Cintas Corporation was monitored for 624 compounds, not listed on the
IDSF forms. We found no problems with the results which are on file and
available if needed.
• Cintas Corporation was inspected on June 19, 2019
• Orders and Schedule Information: None
• A to C and Construction Information: None
Cintas Corporation had the following activities during the Jul.l- Dec.31, 2019 reporting
period:
• Cintas Corporation had one TSS violation this reporting period for which
a Notice of Non -Compliance was issued. The Notice of Non -Compliance
required 2 additional resamples. These resamples were taken by Cintas
Corporation for the parameter and the resamples were both within their
permit limits. They were not in SNC for TSS.
• Cintas Corporation was monitored for 624 compounds, not listed on the
IDSF forms. We found no problems with the results which are on file and
available if needed.
• Orders and Schedule: None
• A to C and Construction Information: None,
2. Luxfer Gas Cylinders Permit No. 2001(Gas Cylinders) 40CFR 467.36
(Aluminum Forming)
235 Riverbend Rd., Graham, N.C. 27253
Luxfer had the following activities during the Jan.l -Jun. 30, 2019 reporting period:
• Luxfer had no violations this reporting period to report.
• Luxfer was monitored for TTO compounds under 40 CFR 467. 36. The
results were all less than detect, therefore, well under the 0.424 mg/L
permit limit.
• Orders and Schedule Information: None
• A to C and Construction Information: None
Luxfer had the following activities during. the Jul. 1-Dec: 31, 2019 reporting period:
• Luxfer had no violations this reporting period to report.

• Luxfer was monitored for TTO compounds under 40 CFR 467. 36. Due to
a high level or organic acids, esters and other non -target compounds
present in the sample the laboratory was unable to achieve lower detection
limits for semi -volatile organic analysis. This sample required a x10
dilution. All values were not detected.
• Luxfer was inspected on October 3, 2019.
• Orders and Schedule Information: None
• A to C and Construction Information: None
3. Novaflex Hose Corp. Permit No. 1001 40 CFR 428 (Rubber Manufacturing)
449 Trollingwood Road, Haw River, N.C. 27258
Novaflex had the following activities daring the Jan. i-Jun. 30, 2019 reporting period:
Novaflex had had one pH violation this reporting period for which a Notice of
Non -Compliance was issued. A resample was taken by Novaflex for the
parameter and the resample was within their permit limits. They were not in SNC
for pH.
Orders and Schedule Information: None
• A to C and Construction Information: None
NovaFlex had the following activities during the July 1- Dec. 31, 2019 reporting period:
• NovaFlex had no violations this reporting period to report.
• Novaflex was inspected on October 31, 2019.
• Orders and Schedule Information: None
• A to C and Construction Information: None
4. Prescient Company,
Inc.
Permit No. 300140
CFR 433.17 (Metal Finisher)
2125 Senator Ralph
Scott
Parkway, Mebane,
NC 27302
Prescient Company, Inc. had the following activities during the Jan. 1- Jun. 30, 2019
reporting period:
• Prescient Company, Inc. had one BOD violation this reporting period for which a
Notice ofNon-Compliance was issued. The Notice ofNon-Compliance required
2 additional resamples. Two resamples was taken by Prescient for the parameter
and the resamples were both within their permit limits. They were not in SNC for
BOD.
• Orders and Schedule Information: None
• A to C AO t, +; n Information: None
• Total Toxic Organics Certification Statement received 6/10/19,
Prescient Company, Inc. had the following activities during the July 1-Dec. 31, 2019
reporting period:

• Prescient Company, Inc. had no violations this reporting period to report.
• Prescient Company, Inc. was inspected on October 9, 2019.
• Orders and Schedule Information: None
• A to C and Construction Information: None
• Total Toxic Organics Certification Statement received 12/2/19.
5. Stericycle, Inc. Permit No. 0030 (Medical Waste)
1168 Porter Ave., Haw River, N.C. 27258
Due to the extremely high levels of matrix interferences present in the Stericycle samples
during samplings events during 2019, the commercial lab which was used for metals was
unable to reach the lower detection limits that are stated in the City of Graham LTMP.
The commercial lab did provide documentation as to the cause of this. This
documentation is kept with the sample results and is available for review if needed.
Stericycle had the following activities during the Jan. 1-Jun. 30, 2019 reporting period:
• Stericycle, Inc. had no violations this reporting period to report.
• Orders and Schedules Information: None
• A to C and Construction Information: None
Stericycle had the following activities during the July 1-Dec. 31, 2019 reporting period:
• Stericycle had no violations this reporting period to report.
• Stericycle was inspected on September 12, 2019.
• Orders and Schedule Information: None
• A to C Information: None
4

Pretreatment Program Info Database
printed on: 12/20/2019
fnr Program Name Graham i
WWTP Name City of Graham
Stream_ Information IWC % at 7010 13.74
_- _ _.
Program Approval Date 08/05/1983 7Q10-Flow cfs / mgd 34 / 21.96
Pretreatment Status 1 Q10 Flow cfs / mgd 27.96 / 18.07
Full Stream Classification WS-V/NSW
Region WSRO Basin Number CPF02
County Alamance. Receiving Stream Name HAW RIVER
NPDES Number NCO021211
NPDES Effective Date Last PAR Rec 02/18/2019 PAR Due Date 03/01/2020 mercury
07l01/2013 Current Fiscal 1631
NPDES Expire Date 05/31/2016 09/06/2018 required
Year PCI Done yes
POTW is Primary WWTP TRUE Last Audit on 09/12/2019 Audit Year Next23/24
Design Flow mgd 3,5000 h Design mgd Is SIU permitted F 7.57 Permitted SIU flow (mgd) [Pt_S]U) .265
WWTP SIU's Program SIUs 5 ..
WWTP CIU's 3 Program CIUs 3 HWA LTMP IWS SUO ERP
date Inactive Date Next Due 09/01/2023 04/02/2023 O7. 0 20
_ 0)/03)202D - - 7� 20
Date Received by DWR 08/30/2018 011,Q74A18- 03/29/2018 09/07/2011
Date Approved _ 10/03/2018
Adopt Date Required
Date Adopted
Info in this Box from P�Contacts
PT -Pro
Formal Name g.Prime Phonel ext Fax
tA/64h20tS 04/04/2018 09/14/2011 94/231�9t2-�
Ql) )3I2o2D o 2 J l y J 20 2LJ
11l01/2011
Date
Date
Date
Attended
Attended
Attended
HWA Wksn
IUP Wkso
PAR Wkso
Ms, Shelby Smith
Prim
336-570-6721
336-513-5502
1/23/2018
5l24/2016
01/2912019
[e-mail]
Pretreatment Coordinator
PO Box 357
27253
Tonya Mann
1
11(336) 570-6721
1
1
11 1/23/2016
t 1112912019
[e-mail]
Utilities Director
1PO Box 357
27253
DWR Central Office Contact ivien Zhong
DWR Regional Contact Jim Gonsiewski
49�

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: City of Graham
2. 'Primary" NPDES Number NC00 21211
or Non -Discharge Permit # if applicable =>
3.
PAR Begin Date, please enter O1/O1/yyyy
3.
_>
1/1/2019
4.
PAR End Date, please enter 12/31/yyyy
4.
=>
12/31/2019
5.
Total number of SIUs, includes ClUs
5.
_>
5
6.
Number of CIUs
6.
_>
3
7.
Number of SIUs with no IUP, or with an expired IUP
7.
=>
0
8.
Number of SIUs not inspected by POTW
8.
_>
0
9.
Number of SlUs not sampled by POTW
9.
_>
0
10,
Number of SIUs in SNC due to lUP Limit violations
10.
_>
0
it.
Number of SIUs in SNC due to Reporting violations
11.
=>
0
12.
Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar
12.
_>
0
13,
Number of CIUs in SNC
13.
_>
0
14.
Number of SIUs included in Public Notice
14.
=>
0
15
Total number of SIUs on a compliance schedule, CO, AO or similar
15.
_>
0
16.
Number of NOVs, NNCs or similar assesed to SIUs
16.
_>
3
17.
Number of Civil Penalties assessed to SIUs
17.
_>
0
18,
Number of Criminal Penalties assessed to SIUs
18.
=>
0
19.
Total Amount of Civil Penalties Collected 19, =>
$
0
20.
Number of IUs from which penalties collected
20.
=>
0
Notes:
AO Administrative Order RIP Industrial User Pretreatment Permit POTW
CN Categorical Industrial User NNC Notice of Non -Compliance SIU
Publicly Owned
Significant
Treatment Works
Industrial User
CO Consent Order NOV Notice of Violation SNC
Significant
Non -Compliance
IU Industrial User PAR Pretreatment Annual Report
revised I/2018: PAR VPS 2018

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Tity of &a4am
P O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
February 27, 2020
PUBLIC NOTICE OF
INDUSTRIES
IN
NON-COMPLIANCE WITH PRETREATMENT STANDARDS FOR
JANUARY 1, 2019 —
DECEMBER
31,
2019:
THERE ARE NO PUBLIC NOTICES FOR THIS TIME PERIOD DUE TO THE FACTTHAT THERE WERE NO
INDUSTRIES IN SIGNIFICANT NON-COMPLIANCE FOR THE JANUARY 1, 2019 THROUGH DECEMBER 31,
2019 REPORTING PERIOD.
Respectfully Submitted,
Shelby S. Smith
City of Graham