NC0066516_Pretreatment Audit_20211228

DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Mr. Michael Wagner
Public Utilities Director
Town of Fuquay-Varina
401 Old Honeycutt Rd.
Fuquay-Varina, NC 27526
NORTH CAROLINA
Environmental Quality
December 28, 2021
Subject: Pretreatment Audit
Town of Fuquay-Varina, Terrible Creek WWTP
NPDES Permit No. NC0066516
Wake County
Dear Mr. Wagner:
On September 28, 2021, Cheng Zhang of the Raleigh Regional Office conducted an audit of
Town of Fuquay-Varina's pretreatment program. The assistance given by Mr. Chris Grimes,
the Public Utilities Operations Manager, and Mr. Adam Stephenson, the Wastewater Treatment
Plant Supervisor, was greatly appreciated. The inspection report is attached. Findings during
the inspection were as follows:
1. The Town has one Significant Industrial User (SIU), which is also a Categorical
Industrial User (CIU). It was noted that the SIU was not in Significant Non -Compliance
(SNC) during the two most recent semi-annual periods.
2. The pretreatment inspection file review included John Deere Turf Care (Permit No.
0003). The files needed for review were available for inspection, contained all the
required elements. In the first half of 2021, the SIU did not have any limit violations, but
was late in submitting monitoring report for the first quarter, and did not submit TTO
certification for the period. The POTW failed to identify these reporting violations.
The POTW needs to take enforcement as required by the Enforcement Response
Plan.
3. A review of the files containing the pretreatment program elements was conducted. All
files were available, up to date, and well organized. Headworks Analysis update was
submitted on August 31, 2020, and is in review by the Division.
4. Long Term Monitoring Plan (LTMP) will resume one year before the next due date for
Headworks Analysis update.
NOR�D_E
�aearbnenl al Environmental 9uallly
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
5. As part of the audit, the inspector watched Mr. Stephenson conduct an inspection of the
lone SIU, John Deere Turf Care. The inspection was very thorough.
Please respond in writing within 30 days of receipt of this letter regarding Item 3. If you
have any questions or comments, please call Cheng Zhang at [phone] (or email:
Cheng. zhang@ncdenr. gov).
Sincerely,
DocuSigned by:
bssittAAA-ssa. f. (ft tAlt (,
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: PT Audit Form
Cc: Central Files w/attachment (Laserfiche)
Raleigh Regional Office w/attachment
Chris Grimes, Town of Fuquay-Varina (electronic copy only)
1:11
NORTH CAROLINA
Ilea.�vm or enwmmnmenteiau.rm\
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
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: Town of Fuquay-Varina
2. Control Authority Representative(s): Chris Grimes; Adam Stephenson
3. Title(s): Public Utilities Operations Manager; Wastewater Treatment Plant Supervisor
4. Address of POTW:
Mailing 1415 Holland Road
City Fuquay-Varina
Phone Number 919-753-1013 Fax Number
Zip Code 27526
E-Mail cgrimes(i/fuquay-varina.org
5. Audit Date 09/28/2021
6. Last Inspection Date: 05/24/2019 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. Ammonia, 2-2021; TP, 6-2020. 3-2020;
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
INICI0I0I6 16 15 11 16 I
10. Current Number of Sivnificant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
09 28 21
1
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)?
19. Number of CIUs in SNC?
1
0
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval 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)
8/31/2020
❑ Yes ❑ No
5/1/2014
❑ Yes ❑ No
5/1/2020
Industrial Waste Survey (IWS)
12/14/2016
❑ Yes ❑ No
3/6/2017
❑ Yes ❑ No
11/1/2021
Sewer Use Ordinance (SUO)
1/29/2014
❑ Yes ❑ No
5/9/2014
❑ Yes ❑ No
Enforcement Response Plan (ERP)
6/10/2020
❑ Yes ❑ No
9/2/2020
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
1/28/2019
❑ Yes ❑ No
3/6/2019
❑ 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 3/4/2013
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 Followine: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
a S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
CS ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Microsoft Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industrial water/sewer rate
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? Need to make an appointment with Utilities 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? Proprietary information and trade secrets are considered confidential
and kept in a locked file.
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)
38. How does the POTW become aware of new or changed Users? From the Town's water billing department, IWS forms
are completed for new users
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
SIU?) Review IWS to determine if the user is a SIU or CIU.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
▪ Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
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)
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 any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ❑ Yes ® No
If yes, what percentage of each parameter % POTW has plenty capacity
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)
Categorical parameters, NPDES POCs, POCs based on activity being performed by Industry
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Have chosen a frequency greater than the minimum required.
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? Spreadsheet for limit violations, postmark dates
for reporting violations.
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.
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?
Chemical storage, floor drains
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA Guidance
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling of batch discharge at process only location
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.
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.
Both POTW and SIU follow Meritech's COC procedure.
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? ® NA
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
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, who completes your HWA? Hazen & Sawyer Phone [phone]
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.
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. Final sludge will be used for composting.
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. John Deere Turf Care
2.
3.
67. IUP Number
0003
68. Does File Contain Current Permit?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
3/31/2024
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. 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
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes❑No❑N/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. 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
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑Yes❑NoON/A
❑ Yes ❑ No
❑ Yes ❑ No
78. 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
79. 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
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoON/A
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
83. 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
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 1 No
❑ Yes ❑ No
❑ Yes ❑ No
85. 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❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No ON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes A No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
79 — The SIU did not submit flow reports for months in which samples were not taken; report for 1 St quarter of 2021 was submitted late;
the SIU did not submit TTO certification for the 1 St semi-annual period of 2021.
82 — The POTW failed to identify these reporting violations
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
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DocuSign Envelope ID: 9CCO9DD7-254D-454C-B16B-2DC32D3CD620
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 16 1 6 1 5 11 1 6 I 109 128 121 I
1. Industry Inspected: John Deere Turf Care
2. Industry Address: 6507 NC-55, Fuquay-Varina, NC 27526
3. Type of Industry/Product: Metal finisher/Turf care equipment
4. Industry Contact: Daniel Budreau Title: Environmental Engineer 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:
POTW representative conducted a thorough inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: POTW failed to identify reporting violations
Requirements: POTW needs to require SIU to submit flow reports for months when samples are not taken; and TTO certification
every six months. POTW needs to take enforcement action for the reporting violations.
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑
Marginal ® Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: 9/28/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 8