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HomeMy WebLinkAboutNC0024945_Inspection_20211004ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Bill Gintert Environmental Compliance Manager Charlotte Water System Protection 4222 Westmont Drive Charlotte, North Carolina 28217 Dear Mr. Gintert: NORTH CAROLINA Environmental Quality October 4, 2021 Subject: Pretreatment Audit Inspection Charlotte Water NPDES Permit No. NC0024549 Mecklenburg County Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of Charlotte Water's Industrial Pretreatment Program on August 25, 2021, by Mr. Wes Bell of this Office. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192, or via email at wes.bell@ncdenr.gov. Enclosure: Inspection Report NORTH Dep®rlmont of Environmental Onolit Sincerely, ,-DocuSigned by: %.---A14CC681AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality 1 Division of Water Resources Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115 704.663.1699 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Background Information: 1. Control Authority (POTW) Name: Charlotte Water 2. Control Authority Representative(s): Bill Gintert, Sarah Daley 3. Title(s): Env. Compliance Manager, Env. Compliance Supervisor 4. Address of POTW: Street/Post Office Box 4222 Westmont Drive City/State/Zip Code Charlotte, NC 28217 Phone Number: (704) 336-4636 Fax Number: 704-336-5077 E-Mail: bgintert@charlottenc.gov 5. Audit Date: 08/25/2021 6. Last Inspection Date: 3/18/20 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. Sugar Creek WWTP — Weekly average CBOD limit violation in February 2020. Mallard Creek WWTP — Weekly average CBOD limit violation in October 2020. McDowell Creek WWTP — Discharge of partially treated wastewater (no disinfection) in June 2021. 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 INICI0I012 I4 I9 I4 I5 I 10. Current Number of Significant Industrial Users (SIUS)? MM/DD/YY 1 08 I25 I21 53 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? 2 13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 4 14. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? 0 15. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods? 1 16. Number of SIUs in SNC with Pretreatment Schedules? 0 17. Number of SIUs on Schedules? 0 18. Current Number of Categorical Industrial Users (CIUS)? 24 19. Number of CIUs in SNC? 0 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 20. PRETREATMENT PROGRAM ELEMENTS REVIEW Program Element: NC0024945 (Irwin Creek WWTP) Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 12/20/19 @ Yes ❑ No 5/12/20 @ Yes ❑ No 10/1/23 Industrial Waste Survey (IWS) 12/20/19 // Yes ❑ No 10/19/20 // Yes ❑ No 12/31/24 Sewer Use Ordinance (SUO) 8/20/12 Yes ❑ No 9/13/12 @ Yes ❑ No Enforcement Response Plan (ERP) 10/11/19 /1 Yes ❑ No 1/7/20 @ Yes ❑ No Long Term Monitoring Plan (LTMP) 5/30/18 // Yes ❑ No 7/6/18 // Yes ❑ No Program Element: NC0030210 (Mallard Creek WWTP) Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 7/31/18 // Yes ❑ No 8/15/18 // Yes ❑ No 6/1/23 Industrial Waste Survey (IWS) 12/20/19 A/ Yes ❑ No 10/19/20 /1 Yes ❑ No 12/31/24 Sewer Use Ordinance (SUO) 8/20/12 // Yes ❑ No 9/13/12 0 Yes ❑ No Enforcement Response Plan (ERP) 10/11/19 // Yes ❑ No 1/7/20 // Yes ❑ No Long Term Monitoring Plan (LTMP) 5/30/18 0 Yes ❑ No 7/6/18 @ Yes ❑ No Program Element: NC0024970 (McAlpine Creek WWTP) Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 11/30/18 // Yes ❑ No 12/5/18 r Yes ❑ No 12/1/23 Industrial Waste Survey (IWS) 12/20/19 0 Yes ❑ No 10/19/20 /1 Yes ❑ No 12/31/24 Sewer Use Ordinance (SUO) 8/20/12 0 Yes ❑ No 9/13/12 r Yes ❑ No Enforcement Response Plan (ERP) 10/11/19 // Yes ❑ No 1/7/20 // Yes ❑ No Long Term Monitoring Plan (LTMP) 5/30/18 0 Yes ❑ No 7/6/18 L Yes ❑ No Program Element: NC0024937 (Sugar Creek WWTP) Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 6/1/18 0 Yes ❑ No 8/14/18 8 Yes ❑ No 4/1/23 Industrial Waste Survey (IWS) 12/20/19 0 Yes ❑ No 10/19/20 // Yes ❑ No 12/31/24 Sewer Use Ordinance (SUO) 8/20/12 0 Yes ❑ No 9/13/12 L Yes ❑ No Enforcement Response Plan (ERP) 10/11/19 // Yes ❑ No 1/7/20 L Yes ❑ No Long Term Monitoring Plan (LTMP) 5/30/18 // Yes ❑ No 7/6/18 0 Yes ❑ No *Charlotte Water — McDowell Creek WWTP has no SIUs. 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. Union County 22. If yes to #22, 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 #22, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA If yes, Explain NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 24. Date of Last SUO Adoption by Local Council 10/28/13 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 El 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? El 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 Followine: S=Satisfacto M=Mareinal U=Unsatisfacto Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program /1 S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and Emergencies /1 S ❑M ❑U Access to Operable Sampling Equipment /1 S ❑M ❑U Availability of Funds if Needed for Additional Sampling and/or Analysis A S ❑M ❑U Reference Materials AS❑M❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) /1 S ❑M ❑U Computer Equipment (Hardware and Software) CS ❑M ❑U 30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Pretreatment Information Management System (PIMS), Hach WIMS. Charlotte Water is in the process of evaluating and approving a new Pretreatment data management system that will be utilized in 2022. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Monthly user fees and surcharges (COD, ammonia, 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. Charlotte Water is in the initial permitting stages for a new regional WWTP (Joe Stowe WWTP). The service areas will be expanded to include the wastewater flows from the City of Belmont and City of Mt. Holly; however, both of these municipalities will still oversee the industrial discharges in their own jurisdictions. Charlotte Water has been working with the Pretreatment staff of both cities regarding IUP limits, etc. 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? The POTW has a full-time Records Administrator (RA) that oversees the record keeping program. The request would be submitted in writing to either the RA or Pretreatment staff. Records are typically emailed by either the RA or Pretreatment staff. Files could also be scheduled to be reviewed at the Westmont Drive Office. 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? Requests would be reviewed/approved by the Pretreatment staff. Confidential information is secured in a database (PIMS) with limited access and any paper copies would be secured in locked file cabinet. NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 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 37. Were all industries in SNC published in the last notice? ® Yes ❑ No ❑ NA Permitting (Industrial Waste Survey-IWS): 38a. How does the POTW become aware of new or changed Users? The POTW's agencies (Economic Development, Chamber of Commerce, Customer Service, Capacity Assurance, etc.) forward information regarding potential new users to the Pretreatment staff for review. Water consumption records and the Manufacturers Registry are also reviewed by Pretreatment staff. 38b. 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 SIU) The Pretreatment staff evaluate the Short Form/Long Form IWS information, any categorical waste streams, pollutant loading, and HWA allocations. The Pretreatment staff also perform site visits to address any concerns in the IWS information. 39. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? ®Yes ❑No If Yes, How many are there? 1 (No groundwater remediation systems) Please list each site and how it is permitted, if applicable. Mecklenburg County Fox Hole Landfill (construction debris); SIU. 40. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA 41. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) Designated point (McAlpine Creek WWTP), quarterly samples drawn from each truck, manifests required, all septage trucks have specific identification information. 42. How does the POTW allocate its loading to industries? Mark all that apply El Uniform Limits ® Historical Industry Need El By Surcharge ® Categorical Limits ❑ Other Explain Other: 43. 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? Silver 44. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.) Charlotte Water continues to work with the Division to address this issue. Charlotte Water has been performing additional sampling (collection system and wastewater treatment processes) and has incorporated a lower analytical detection level. 45. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes El No If yes, what percentage of each parameter? 10% — 20% 46. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No If yes, Explain. 47. 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) Categorical parameters, POCs, surchargeable parameters. 48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. >10% MAHL — monthly monitoring; 5-10% of MAHL — quarterly monitoring; twice per year monitoring at a minimum. POTW performs quarterly monitoring (minimum) at all SIUs. Permit Compliance: 49. Does the POTW currently have or during the past year had any permits under adjudication? ® Yes El No If yes, which industries? What was (will be) the outcome of the adjudication? Union County appealed their IUP. Charlotte Water has resolved all issues with Union County and the IUP has been reissued. 50. 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 with IUPs determined by the Pretreatment Compliance Specialists. Compliance Judgment Worksheet used for SNC determinations, ERP followed for all violations (limits, monitoring, reporting, permit conditions). NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 51. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, does the POTW form include all DWQ data? ❑ Yes El No 52. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes El No If no, Explain. 53. What criteria are used to determine if a slug/spill control plan is needed? All SIUs required to have slug/spill control plan. 54. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Emergency contacts up to date, adequate storage practices/secondary containment structures, presence of emergency response equipment. 55. How does the POTW decide where the sample point for an SIU should be located? Pretreatment system effluent prior to combining with domestic wastewater preferred. Ease of staff access and compatibility with sampling equipment also included in decisions for sampling locations. 56. 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 El No SIU: ® Yes El No If yes, Explain. Charlotte Water's certified laboratory staff performs all SIU sampling according to SOPs; SIU sampling protocols are reviewed during inspections. 57. Who performs sample analysis for the POTW for Metals — Charlotte Water Laboratory Services Conventional Parameters - Charlotte Water Laboratory Services Organics - Charlotte Water Laboratory Services 58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Charlotte Water uses internal certified laboratory COC form and field measurement record form (FMRF); SIUs also use Charlotte Water's COCs and FMRFs along with the contracted commercial laboratory's COC. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA): 59a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO 59b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO 59c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES El NO Is Table Adequate? ® YES El NO 59d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ Inspector, verify yourself! 59e. If NO to any above, list violations 59f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: 60. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No If no, Who completes your HWA? 61. 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 EINPDES limits change DMore LTMP data available ❑Resolve over allocation 05 year expiration ['Other, explain. 62. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ['Sludge Quality 63. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No Explain. New WWTP (Joe Stowe WWTP) will be constructed in the near future. Summary: 64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW: 65. User Name 1. Charlotte Pipe & Foundry 2. Frito Lay 3. Allied Metal 66. IUP Number 0665 0618 5005 67. Does File Contain Current Permit? /1 Yes ❑ No /1 Yes ❑ No 0 Yes ❑ No 68. Permit Expiration Date 10/31/25 4/30/25 7/31/26 69. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433 & 464 N/A 433 70. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? /1 Yes ❑ No /1 Yes ❑ No r Yes ❑ No 71. Does File Contain Inspection Completed Within Last Calendar Year? /1 Yes ❑ No /1 Yes ❑ No /1 Yes ❑ No 72. a. Does File Contain Slug/Spill Control Plan? b. If No, is One Needed? (See Inspection Form from POTW) a. Yes •No b. •Yes •No a. Yes •No b. •Yes •No a. Yes ■No b. •Yes •No 73. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic Organic Management Plan (TOMP)? ®Yes❑No❑N/A ❑Yes❑NoON/A ®Yes❑No❑N/A 74. a. Does File Contain Original Permit Review Letter from Division? b. All Issues Resolved? a. Yes •No b.❑Yes❑No®N/A a. Yes •No b.❑Yes❑No®N/A a. Yes •No b.❑Yes❑No®N/A 75. During Most Recent Semi -Annual Period, Did POTW Complete its Sampling as Required by IUP, including Flow? /1 Yes ❑ No /1 Yes ❑ No /1 Yes ❑ No 76. Does File Contain POTW Sampling Chain -Of -Custody Forms? Al Yes ❑ No Al Yes ❑ No L Yes ❑ No 77. During Most Recent Semi -Annual Period, Did SIU Complete its Sampling as Required by IUP, including Flow? ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A 78. During Most Recent Semi -Annual Period, Did SIU submit all reports on time? ®Yes❑No❑N/A ❑Yes®No❑N/A ®Yes❑No❑N/A 79a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? ®Yes❑No❑N/A ❑Yes❑NoON/A ❑Yes❑NOON/A 79b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑NOON/A 80. During Most Recent Semi -Annual Period, Did POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? ❑Yes❑NoON/A ®Yes❑No❑N/A ❑Yes❑NOON/A 81. During Most Recent Semi -Annual Period, Did POTW Identify All Reporting Non -Compliance from SIU Sampling? ❑Yes❑NoON/A ®Yes❑No❑N/A ❑Yes❑NoON/A 82. a. Was POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resample and submit results to POTW within 30 Days? c. If applicable, did POTW resample and obtain results within 30 days of becoming aware of SIU limit violations in the POTW's sampling of SIU? a.❑Yes❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A a.❑Yes❑No❑N/A b.❑Yes❑No®N/A c.❑Yes❑No®N/A 83. During Most Recent Semi -Annual Period, Was SIU in SNC? ❑ Yes /1 No 1 ❑ Yes /1 No ❑ Yes L No 84. During Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? ❑Yes❑No®N/A ®Yes❑No❑N/A ❑Yes❑NoNN/A 85. Does File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoON/A 86. Does File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑NoON/A ❑Yes❑NoNN/A 87. a. Does File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? a.❑Yes❑No®N/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A a.❑Yes❑No®N/A b.❑Yes❑No®N/A 88. Did POTW Representative Have Difficulty in Obtaining Any Requested Information For You? ❑ Yes 1 No ❑ Yes 1 No ❑ Yes r No FILE REVIEW COMMENTS: 15. Brenntag Mid -South was in SNC during first half of 2021 for CBOD violations (TRC). 71. SIU inspections were performed on 8/26/20 (Charlotte Pipe & Foundry), 8/27/20 (Frito Lay) and 8/12/20 (Allied Metal). 75. Charlotte Water's certified laboratory performs all IUP-required analyses (Charlotte Water and SIU sampling). 78. Charlotte Water issued NOVs to Frito Lay for violations in January 2021 (TSS) and June 2021 (late reporting). NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number 0 0 2 4 9 4 5 MM/DD/YY 25 (DTIA) 8 21 Inspection type U (TYPI) 1. Industry Inspected: Charlotte Pipe & Foundry 2. Industry Address:1335 South Clarkson Street, Charlotte, NC 28235 3. Type of Industry/Product: Metal Finisher/Foundry; Cast Iron Pipe/Fittings /4. Industry Contact: Jenny Pappalardo Title: Environmental Engineer Phone: (704) 348-5513 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 Inspector Facility Type S 2 (INSP) (FACC) Industrial Inspection Comments: The facility currently has 522 employees and operates two eight -hour shifts, five days per week. The foundry melts approximately 150,000 tons per year and produces approximately 10,000 to 12,000 pipe (cast iron) per day. Every metal scrap load (railcar, trailer, etc.) is tested for radiation and inspected for unwanted materials including aluminum, lead and mercury. Off -spec materials (not reused) are disposed at a permitted landfill. The Pretreatment system includes screening, influent sump/pumps, pH adjustment, coagulation/flocculation, clarification, sludge conditioning, sludge dewatering and flow measurement. Approximately 500,000 to 600,000 gallons of treated wastewater is recycled per day. Dewatered sludge is disposed at a permitted landfill. The Company has contracted Hepaco for spill cleanup and Heritage Crystal Clean for removal/disposal of used oils. SUMMARY AND COMMENTS: Charlotte Water has a policy to accept composite samples within +/- two (2) hours of the required 24-hr. sampling period. All efforts should be made to collect composite samples over a 24-hr. period; however, composite samples may be accepted if the sampling period is deviated by less than one hour. Charlotte Water staff must ensure all applicable SIUs are informed of this sampling clarification. The records reviewed during the inspection were organized and well maintained. Charlotte Water's Industrial Pretreatment Program was being properly managed and implemented. NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory Audit COMPLETED BY: Marginal 111 Unsatisfactory ❑ A61696D90CC3437... Wes Bell, Sr Environmental Specialist, WQROS/Mooresville Regional Office DATE: 10/4/2021 AUDIT REVIEWED BY: LE0DocuSignedd by: 1G1 �DocuSigned by: '-A14CC681AF27425... DATE: 10/4/2021 Corey Basinger, Regional Supervisor, WQROS/Mooresville Regional Office NC DWR Pretreatment Audit Form Revised: December 2016 Page 7