NC0037834_Pretreatment Compliance Audit Inspection Letter_20201202

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Joel Freeman
Utility Plant Supervisor
City of Winston-Salem
Manson -Meads Complex
2799 Griffith Road
Winston-Salem, North Carolina 27103
NORTH CAROLINA
Environmental Quality
December 2, 2020
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Winston-Salem
NPDES# NCO037834
Forsyth County
Dear Mr. Freeman:
On November 17, 2020 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski
and Alex Lowe of the Winston-Salem Regional Office. Mr. Joel Freeman, Mr. Olu Browne, and Mr.
Michael Gearren were present for the inspection. The purpose of this inspection was to determine the
effectiveness of the Town's pretreatment program, which includes reviewing the files, POTW plant
performance, industry monitoring data, and adherence to the enforcement response plan (ERP).
Background
This is a 51 MGD permitted facility with the Archie Elledge and Muddy Creek facilities. The City has
twenty eight (28) Significant Industrial Users of which ten (10) are Categorical Industrial Users regulated
per CFR 433. One facility (Environmental Relief Technologies) was added as an SIU in September 2019.
POTW Interview
There are no plant problems related to pretreatment issues. There were NPDES permit limit violations
recorded at the Muddy Creek facility for flow volumes in February 2020 and solids in October 2020 due to
weather and the resulting inflow and infiltration. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on October 2, 2017. The HWA was approved on
February 28, 2018. The next HWA is due on October 1, 2022.
The Industrial Waste Survey (IWS) was submitted on July 1, 2016. The IWS was approved on September
2, 2016. The next IWS is due on July 1, 2021.
The Sewer Use Ordinance (SUO) was approved on February 9, 2012.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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The Enforcement Response Plan (ERP) was approved on February 5, 2020.
LTMP File Review
The Long Term Monitoring Plan (LTMP) was approved on March 5, 2019 and is being conducted at the
proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for WestRock (#3041) revealed that the monitoring data was well organized and
compliant.
A review of the file for Lantal (#3102) revealed that the monitoring data was well organized and compliant.
A review of the file for Progress Rail (#1038) revealed that the monitoring data was well organized and
compliant.
The slug control plan for WestRock (#3041) was in good order.
The slug control plan for Lantal (#3102) was in good order.
The slug control plan for Progress Rail (#1038) was in good order.
Action Items
During the reporting period, exceedances of cyanide were noted in the second half of 2019 at Stratford
Metals. Exceedances of lead were noted at Clarios in the first half of 2020. Exceedances of BOD were
noted at Suiza Dairy in the first half of 2020. These exceedances caused the facilities to be in Significant
Non -Compliance.
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Freeman conducts an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
Docu SiTgnedl�by:
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Lon T. ruder
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enclosure: PCI Report
cc: PERCS Unit — Mike Montebello (Electronic Copy)
WSRO Electronic Files
Laserfiche Files